Also known as: Erie doctrine · Erie rule · Erie
Written by attorneys · grounded in primary & secondary sources — see below
A body of decisional law that governs choice between state and federal rules in diversity cases. Federal courts apply state law on issues that are substantive under the outcome-determination test or balance-of-interests analysis and apply federal rules when a valid Federal Rule of Civil Procedure is on point.
Emma Erickson sued Evergreen Bank in federal court after a loan dispute. No federal statute addressed the burden of proving commercial custom. The court weighed the state's interest in uniform application of its commercial rules against the federal interest in efficient fact-finding and decided to follow the state rule.
Eduardo Enriquez filed a contract claim in federal court one day after the state statute of limitations had run. The federal court applied the state tolling rule because disregarding it would have produced a different result than the same suit filed in state court.
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Elijah Edwards served process on Elysium Media by leaving papers at the corporate office. Although state law required personal delivery to an officer, the federal court upheld service under the Federal Rule because the rule was valid and arguably procedural.
Ella Emerson sued Equinox Energy in the federal court of State A for a contract formed in State B. The court applied State A's choice-of-law rules to select which state's substantive contract law governed the dispute.
Evelyn Ellison was injured by a train while walking on railroad property in State C. The federal court refused to create a federal standard of care and instead applied the duty rules developed by State C's courts.
Eva Espinosa sued Eastern Electric in federal court for negligence occurring in State D. The court looked to State D's decisions on landowner duties rather than fashioning an independent federal rule of decision.
The court applies the outcome-determination test and, if needed, weighs the respective interests of the state and the federal judicial system under the balance-of-interests approach.
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Yes. Statutes of limitations and their tolling rules are treated as substantive, so the federal court must follow them to avoid materially different outcomes from state court.
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The federal rule controls if it is arguably procedural and valid under the Rules Enabling Act, even when it produces a different result from the state practice.
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The diversity court must apply the choice-of-law rules of the state in which it sits because those rules are substantive for Erie purposes.
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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…