Also known as: Erie doctrine · Erie Railroad · Erie Railroad Co. v. Tompkins
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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.
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.
Harry Tompkins, a citizen of Pennsylvania, was injured on a dark night by a passing freight train of the Erie Railroad Company while walking along its right of way at Hughestown in that State. He claimed that the accident occurred through negligence in the operation or maintenance of the train. He also claimed that he was rightfully on the premises as a licensee because he was on a commonly used beaten footpath which ran for a short distance alongside the tracks. To enforce that claim he brought an action in the federal court for southern New York, which had jurisdiction because the company is a corporation of that State. The Erie Railroad Company denied liability, and the case was tried by a jury. The railroad insisted that its duty to Tompkins was no greater than that owed to a trespasser. It contended that under the law of Pennsylvania, as declared by its highest court, persons who use pathways along the railroad right of way are to be deemed trespassers. The railroad further contended that it is not liable for injuries to undiscovered trespassers resulting from its negligence unless the conduct is wanton or wilful. Tompkins denied that any such rule had been established by the decisions of the Pennsylvania courts. He contended that since there was no statute of the State on the subject, the railroad's duty and liability is to be determined in federal courts as a matter of general law. The trial judge refused to rule that Pennsylvania law precluded recovery. The jury brought in a verdict of $30,000, and the judgment entered thereon was affirmed by the Circuit Court of Appeals. The Erie had contended that application of the Pennsylvania rule was required by section 34 of the Federal Judiciary Act of September 24, 1789. Because of the importance of the question whether the federal court was free to disregard the alleged rule of the Pennsylvania common law, the Supreme Court granted certiorari.
View caseElise 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.
Tompkins, a citizen of Pennsylvania, was injured on a dark night by a passing freight train of the Erie Railroad Company while walking along its right of way at Hughestown in that State. He claimed that the accident occurred through negligence in the operation or maintenance of the train. He asserted that he was rightfully on the premises as a licensee because he was on a commonly used beaten footpath which ran for a short distance alongside the tracks. He further alleged that he was struck by something which looked like a door projecting from one of the moving cars. To enforce that claim he brought an action in the federal court for southern New York, which had jurisdiction because the company is a corporation of that State. The Erie insisted that its duty to Tompkins was no greater than that owed to a trespasser. It contended, among other things, that its duty to Tompkins, and hence its liability, should be determined in accordance with the Pennsylvania law; that under the law of Pennsylvania, as declared by its highest court, persons who use pathways along the railroad right of way are to be deemed trespassers; and that the railroad is not liable for injuries to undiscovered trespassers resulting from its negligence, unless it be wanton or wilful. Tompkins denied that any such rule had been established by the decisions of the Pennsylvania courts. He contended that, since there was no statute of the State on the subject, the railroad's duty and liability is to be determined in federal courts as a matter of general law. The trial judge refused to rule that the Pennsylvania law precluded recovery. The jury brought in a verdict of $30,000. The judgment entered thereon was affirmed by the Circuit Court of Appeals, which held that it was unnecessary to consider whether the law of Pennsylvania was as contended, because the question was one not of local, but of general, law and that upon questions of general law the federal courts are free, in the absence of a local statute, to exercise their independent judgment as to what the law is. Because of the importance of the question whether the federal court was free to disregard the alleged rule of the Pennsylvania common law, the Supreme Court granted certiorari.
View caseA 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.