Also known as: Erie doctrine · Erie Railroad · Erie Railroad Co. v. Tompkins
Written by attorneys · grounded in primary & secondary sources — see below
A doctrine requiring federal courts sitting in diversity jurisdiction to apply state substantive law rather than federal common law. The doctrine distinguishes substantive rules that affect outcomes from procedural rules that govern the conduct of litigation in federal court.
Ethan Evans sued Elite Dynamics in federal court in New York after a contract dispute. No federal rule addressed the admissibility of certain internal corporate memos. The court weighed New York's strong interest in regulating local business conduct against the federal system's interest in uniform evidence handling and decided to apply the state rule.
Emily Ellis filed a personal injury claim in federal court in Pennsylvania one day after the state statute of limitations expired. Pennsylvania's tolling rule would have saved the claim. The federal court applied the state limitations period and dismissed the action.
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Emma Erickson commenced a diversity action in federal court. A Federal Rule of Civil Procedure permitted service by mail while state law required personal service. The court applied the federal rule because it was valid and arguably procedural.
Eva Espinosa sued Everest Holdings in federal court in Illinois over a contract formed in Indiana. Illinois choice of law rules pointed to Indiana substantive law. The federal court applied Illinois conflict rules to select the governing state law.
Ewan Eckhart brought a negligence claim in federal court based on diversity. The defendant argued for a federal common law standard of care. The court refused and applied the state negligence standard instead.
Elise Everly sued Eastern Electric in federal court after an accident on state land. The defendant urged adoption of a federal rule of decision. The court held that state law supplied the rule of decision for the substantive claim.
A federal court sitting in diversity must apply state substantive law when no controlling federal statute or valid Federal Rule of Civil Procedure addresses the issue.
An issue is substantive if applying federal law instead of state law would substantially alter the result of the litigation compared with the result in state court.
Courts apply the balance-of-interests test by weighing the state's interest in its rule against the federal judicial system's interest in its own practice.
Yes. Choice of law rules are treated as substantive, so a federal court applies the conflict rules of the state in which it sits.
Yes. When a Federal Rule is on point and valid under the Rules Enabling Act, it governs even if it differs from state procedure.
Erie Railroad Co. v. Tompkins <!-- acedexams opinion md v1 -- Case information - Citation: 304 U.S. 64, 78–80 (1938) Majority opinion Opinion of Mr. Justice Brandeis The question for decision is…