LEGAL PRINCIPLE: APPELLATE PRACTICE – Concurrent Findings of Fact – When the Supreme Court will Interfere
PRINCIPLE STATEMENT
The appeal is against two concurrent findings of two lower courts; this court will not interfere with their findings; the appellants have not shown any special circumstances that would justify such interference.
RATIO DECIDENDI (SOURCE)
"The appeal is against two concurrent findings of two lower courts. This court will not interfere with their findings. The appellants have not shown any special circumstances that would justify such interference."
EXPLANATION / SCOPE
This reinforces the concurrent findings doctrine (Principles 216, 248, 283). When trial and appellate courts agree on factual findings, Supreme Court interference requires “special circumstances.” The burden is on appellants to demonstrate such circumstances—they must affirmatively show: findings are perverse, unsupported by evidence, resulted from wrong approach to evidence, or involved misapplication of legal principles. Mere disagreement with findings or alternative interpretations of evidence don’t constitute special circumstances. The double concurrence creates strong presumption of correctness—two courts independently reached the same conclusions after examining evidence. This presumption serves: finality (disputes must end), efficiency (preventing endless fact re-examination), and respect for lower courts’ fact-finding roles. Without demonstrating special circumstances, concurrent findings stand as final. This places high burden on Supreme Court appellants—they cannot merely argue the facts, but must show fundamental error justifying the extraordinary step of disturbing concurrent findings.