International Energy Ventures Management, L.L.C. v. United Energy Group, Ltd.

Whether a reviewing court must strictly adhere to Federal Rule of Civil Procedure 52(a)"s requirement that a district court"s fact-findings "must not be set aside unless clearly erroneous," as the U.S. Court of Appeals for the 1st, 8th, 9th, and District of Columbia Circuits have held, or whether the appellate court may engage in its own review with less deference (or "no" deference, as the U.S. Court of Appeals for the 5th Circuit held below) when the court of appeals decides the fact-findings are insufficient, as the U.S. Courts of Appeals for the 2nd, 5th, 6th, and 11th Circuits have concluded.