Summary of Salve Regina College v. Russell, U.S. Supreme Court (1991)
Cause of action: The following is a cause of action for reviewability of a district court’s determination of law, arising out of a contract dispute.
Procedural History: Original court U.S. District Court for District of RI, with several charges, including nonperformance by the college of its implied agreement to educate respondent. Subject matter jurisdiction in the District Court was based on diversity of citizenship. Parties agree that the law of RI applies to all substantive aspects of the action. District Court denied college’s motion for directed verdict on breach of K claim as there was still a factual issue regarding substantial performance by PL in her overall contractual relationship at the school.
At close of trial, DF again moved for directed verdict, arguing under RI law, the doctrine of substantial performance did not apply in the general academic context. District Court denied petitioner’s motion, and the judge decided to use law from the Supreme Court of RI for application of the doctrine to the facts.
Jury returned verdict for Russell, which was appealed by both parties, and upheld in U.S. Court of Appeals for the 1st Circuit, holding that the doctrine of substantial-performance does apply in the college-student context, and that the district court’s application of RI Supreme Court case law was not reversible error. Court grants certiorari and reverses.
Facts: Contract dispute between a school and one of its students over a weight loss contract instituted by a nursing school on one of its students. Student failed parameters of the weight loss contract and was asked to leave the school, which she did.
Issue(s): Under civil procedure, can a federal court of appeals review a district court’s determination of state law under a standard less probing than that applied to a determination of federal law?
Court’s Rationale/Reasoning: Independent appellate review of legal issues best serves the dual goals of doctrinal coherence and economy of judicial administration. District court trials are faster paced, while appellate courts have a little more breathing room, and time to deliberate over matters, and the record is all nice and neat for the judges to review. They must pour over the record, however, to make sure their analysis was the one which should be applied in a particular case.
Such lack of analysis by the appellate court falls below one standard set forth in the Erie doctrine, which is the avoidance of inequitable administration of the laws, which, if the appellate courts do not review the record but just the decision, can happen.
Respondent Russell argues the appellate courts are deciding de novo; just b/c it is the decision doesn’t mean there is an inequitable administration of law. Respondent also argues that district judges are better arbiters of unsettled state law b/c they have exposure to the judicial system of the State in which they sit. Both contentions are rejected.
Rule: As a general matter, the courts of appeals are vested with plenary (absolute/complete) authority over final decisions of district courts.
Federal appellate rule 52(a): a trial court’s findings of fact “shall not be set aside unless clearly erroneous, and due regard shall be given to the opportunity of the trial court to judge of the credibility of the witnesses.”
Holding: No. A court of Appeals should review de novo a district court’s determination of state law. Appellate courts must independently review a lower court’s determinations.
De novo: over again: as if for the first time: as
a: allowing independent appellate determination of issues (as of fact or law)
Example: a de novo review
b: allowing complete retrial upon new evidence
Note: A de novo review is an in-depth review. Decisions of federal administrative agencies are generally subject to de novo review in the U.S. District Courts, and some lower state court decisions are subject to de novo review at the next level.