Quick Summary
When Harry Tompkins (P) was walking along railroad tracks in July 1934, he was struck by a passing train’s open cabin door and lost his right arm. Tompkins sued Erie Railroad Co. for his injury and train’s negligent conduct. Erie argued that Tompkins was a trespasser and they are not liable unless it was “willful” negligence.
The issue that was presented to the court was which law the federal court should follow.
The Supreme Court ruled that state laws should be applied in all circumstances except when explicit federal regulation applies.
Facts of the Case
In July 1934, Pennsylvania resident Harry Tompkins (plaintiff) was walking along the railroad tracks when the open cabin door of a passing train struck him, knocking him to the ground and amputating his right arm.
Tompkins sued Erie Railroad Co. (defendant) for negligence. Erie argued that Tompkins was a trespasser, and under Pennsylvania law, they are not liable unless it was “willful” negligence.
Tompkins argued that Erie’s obligations and liabilities should be governed by federal common law. The trial judge relied on Swift v. Tyson, 41 U.S. (16 Pet.) 1, which held that federal courts were only required to observe state statute and customary law, not state common law.
The district court ruled in Tompkins’ favor because the majority opinion held that the railroad owed passengers like Tompkins a duty of ordinary care. The circuit court agreed with Tompkins’ appeal and upheld the verdict, stating that federal courts have broad authority to decide general law issues. Certiorari was granted by the United States Supreme Court.
Procedural Posture and History
- Tompkins files a lawsuit in federal court based on diversity jurisdiction.
- The federal court rules in favor of Tompkins, awarding him $30,000 in damages.
- The Erie Railroad Company appeals to the Circuit Court of Appeals, which affirms the decision.
- The case is then brought before the Supreme Court on certiorari.
I.R.A.C. Format
Issue
Does a federal court with varying jurisdiction follow the state’s substantive law, the law of the forum state, or the law of the Federal court in the state where the case was filed?
Rule of Law
Federal courts sitting in diversity jurisdiction must apply the substantive law of the states and federal procedural law, overruling the previous doctrine that allowed federal courts to apply a ‘general common law’.
Reasoning and Analysis
The Supreme Court, led by Justice Brandeis, recognized the problems caused by the Swift v. Tyson doctrine, which allowed federal courts to disregard state common law in favor of a general common law.
This practice led to inconsistency and forum shopping as litigants would seek out federal courts that might rule more favorably on their case, regardless of the relevant state law.
The Court concluded that this approach was unconstitutional and that the correct application of law should be based on the law of the state where the issue arose. By doing so, the Supreme Court aimed to ensure more predictable and just outcomes for litigants and reduce the strain on judicial resources caused by forum shopping.
Conclusion
The Supreme Court reversed the decision of the Circuit Court of Appeals and remanded the case for further proceedings consistent with its opinion, ultimately leading to the dismissal of Tompkins’ case under Pennsylvania law.
Dissenting Opinions
Justice Butler and Justice McReynolds dissented, arguing that neither party raised a constitutional question and that the Court’s decision overstepped its bounds by addressing an issue not contested by the parties involved.
Key Takeaways
- The Supreme Court overruled Swift v. Tyson, ending the practice of federal courts applying ‘general common law’ in diversity cases.
- The ruling established that federal courts must apply state substantive law when deciding cases under diversity jurisdiction.
- The decision addressed concerns about forum shopping and aimed at creating more consistency in the application of law across state and federal courts.
Relevant FAQs of this case
What is the impact of the Erie doctrine on the choice of law in federal courts?
The Erie doctrine mandates that federal courts must apply state substantive laws in cases where they have jurisdiction based on diversity of citizenship. This ensures uniform application of laws and reduces forum shopping, as federal courts can no longer apply a federal general common law that differs from state laws. The choice of law in federal courts is thus directly influenced by the relevant state’s legal precedents and statutes.
- For example: If a contract dispute arises and is brought to a federal court under diversity jurisdiction, and the applicable state law requires written contracts for certain agreements, the federal court must apply this state requirement despite any differing federal rules.
What is the Erie doctrine choice of law?
The doctrine states that federal courts must take state law into account when determining whether federal or state law applies to a certain scenario. When analyzing claims in litigation involving citizens of various states, federal courts must adhere to state law rather than “federal common law.”
Who won Erie vs. Tompkins?
The United States Supreme Court ruled in favor of Erie Railroad by a majority of 6 to 2 on April 25, 1938. This ruling overturned Swift v. Tyson and found that U.S. federal courts must consider state law rather than “federal common law” when adjudicating claims in litigation involving citizens of different states.
References
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