3. Should the standard of review be the same for findings of fact based on demeanor evidence as for documentary evidence? In ANDERSON v. CITY OF BESSEMER CITY, 470 U.S. 564, 105 S.Ct. 1504, 84 L.Ed.2d 518 (1985), the Supreme Court rejected the view that an appellate court “may exercise de novo review over findings not based on credibility determinations * * *”:

The rationale for deference to the original finder of fact is not limited to the superiority of the trial judge’s position to make determinations of credibility. The trial judge’s major role is the determination of fact, and with experience in fulfilling that role comes expertise. Duplication of the trial judge’s efforts in the court of appeals would very likely contribute only negligibly to the accuracy of fact determination at a huge cost in diversion of judicial resources. * * * As the Court has stated in a different context, the trial on the merits should be “the ‘main event’ * * * rather than a ‘tryout on the road.’ ”