Summary of Erie Railroad Co. v. Tompkins, U.S. Supreme Court (1938)
Cause of action: The following is a cause of action for negligence, which turns into a cause of action for federal jurisdiction in a federal court.
Procedural History: Circuit Court of Appeals ruled that the question of liability is one of general law; and on that ground declined to decide the issue of state law. Reversed at Supreme Court..
Facts: PL/respondent, an OH resident, was struck by DF’s train in PA. PL decides to sue in federal court for Southern NY, as the corporation is a resident there.
Issue(s): Under federal rules of civil procedure, does an injured PL who is a citizen of PA and injured in NY, have a right to enjoy the application of federal law to its cause of action in a diversity claim?
Court’s Rationale/Reasoning: The original rule was based on the doctrine of Swift v. Tyson, which held state laws were trumped by federal law where there is a diversity claim, which created an independent judgment in federal courts. The lines were blurred regarding which court’s rules would prevail in these instances, and unwritten “general laws” varied according to whether their enforcement was on a federal or state level. That is, until recent historical research revealed the true meaning of the rule, which is that “the purpose of the section was merely to make certain that, in all matters except those in which some federal law is controlling, the federal courts exercising jurisdiction in a diversity of citizenship cases would apply as their rules of decision the law of the state, unwritten as well as written.
Rule: Except in matters governed by the Federal Constitution or by acts of Congress, the law to be applied in any case is the law of the state.
Holding: No. The court should have federal jurisdiction over a federal question. This case involves state law, and the state should somewhat trump the old acts of Congress
Dissenting: (Justice Butler) The Court shouldn’t take this case, as it does not deal with a non-constitutional issue. The parties should have drawn up their complaint to section34.
Concurring: (reed, in part) Agrees with the decision and the reasoning of the majority. However, in light of the Court’s stare decisis rule, the court did the right thing overturning Swift and subsequently the Act.