499 U.S. 225 (1991)
Salve Regina College is an institution of higher education located in Newport, Rhode Island.1 Sharon L. Russell was admitted to the college and began her studies as a freshman in 1982.2 The following year, Russell sought admission to the college’s nursing department to pursue a bachelor of science degree in nursing.3 She was accepted by the department and began her nursing studies in the fall of 1983.4
Russell was five feet six inches tall and weighed in excess of 300 pounds when she was accepted in the nursing program.5 Her weight became a topic of commentary and concern by officials of the nursing program immediately after the 1983 school year began.6 Her first year in the program was marked by a series of confrontations and negotiations concerning her obesity and its effect upon her ability to complete the clinical requirements safely and satisfactorily.7
During her junior year, Russell signed a document that was designated as a contract.8 The contract conditioned her further participation in the nursing program upon weekly attendance at a weight-loss seminar and a realized average loss of two pounds per week.9 When she failed to meet these commitments, she was asked to withdraw from the program and did so.10
Russell transferred to a nursing program at another college but had to repeat her junior year in order to satisfy the transferee institution’s two-year residency requirement.11 She also underwent surgery for her obesity.12 In 1987, Russell successfully completed her nursing education and is now a registered nurse.13
Soon after leaving Salve Regina College, Russell filed this civil action in the United States District Court for the District of Rhode Island.14 She asserted claims based on intentional infliction of emotional distress, invasion of privacy, and nonperformance by the college of its implied agreement to educate her.15 Subject-matter jurisdiction in the District Court was based on diversity of citizenship.16 The parties agree that the law of Rhode Island applies to all substantive aspects of the action.17
At the close of plaintiff-respondent’s case in chief, the District Court directed a verdict for the individual defendants on all three of the remaining claims and for the college on the claims for intentional infliction of emotional distress and invasion of privacy.18 The court denied the college’s motion for a directed verdict on the breach-of-contract claim.19
At the close of all the evidence, the college renewed its motion for a directed verdict on the contract claim.20 The District Court denied the motion and submitted the breach-of-contract claim to the jury.21 The jury returned a verdict for Russell and determined that the damages were $30,513.40.22 Judgment was entered.23
The United States Court of Appeals for the First Circuit affirmed the judgment.24 The Supreme Court granted certiorari to resolve the conflict among the circuits concerning the appropriate standard of appellate review.25
Whether a federal court of appeals may review a district court’s determination of state law under a standard less probing than that applied to a determination of federal law?26
Under Erie and principles of appellate jurisdiction, a court of appeals must review de novo a district court’s determination of state law.27
No. The courts of appeals are vested with plenary appellate authority over final decisions of district courts, and independent appellate review of legal issues best serves the dual goals of doctrinal coherence and economy of judicial administration.28 The District Court determined that Rhode Island law would apply the doctrine of substantial performance to the contract between Salve Regina College and Sharon L. Russell despite the academic context.29 The Court of Appeals for the First Circuit affirmed by according deference to the District Court’s interpretation based on the judge’s experience as a state trial judge.30
This deferential approach is inconsistent with the duty of appellate courts to provide meaningful review of state-law determinations, as the bases of state law are presumed to be communicable to appellate judges as well as district judges.31
The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.32
Related opinions on this issue
Chief Justice Rehnquist dissented, contending that the Court of Appeals properly accorded deference to the district judge’s experience with Rhode Island law when predicting how the state supreme court would rule on an unsettled question.33 He argued that a district judge’s familiarity with local judicial practices and trends provides valuable insight that appellate judges lacking such experience should weigh. This practical allocation of resources does not abdicate the appellate court’s responsibility but instead reflects sensible judgment in diversity cases.34