Also known as: Hanna · Hanna v. Plumer Part I
Written by attorneys — see sources below.
A principle of federal civil procedure holding that a valid Federal Rule of Civil Procedure governs in a diversity case even when it conflicts with a state rule. The federal rule controls provided it is at least arguably procedural and consistent with the Rules Enabling Act.
Hannah Hughes sued the executor of an estate in federal court under diversity jurisdiction. She served process under Federal Rule of Civil Procedure 4(d)(1) by leaving copies at the executor's home with a person of suitable age. The executor moved to dismiss for improper service under a stricter state statute. The court denied the motion because the federal rule was on point and valid.
Heidi Henderson obtained a large verdict in a diversity case. The defendant moved for a new trial or remittitur citing a state standard that required the court to set aside awards deviating materially from reasonable compensation. The district court applied the state standard to the motion but used federal abuse-of-discretion review on appeal. The federal rule on the mode of review controlled.
Hazel Hoffman filed a habeas petition in federal court after a state conviction. A state rule required filing within a shorter period than Federal Rule of Civil Procedure 3 allowed. The court applied the federal timing rule because it was valid and on point in the federal proceeding.
Hope Howard won a judgment in federal diversity court. The defendant appealed and posted a bond. A state statute imposed an automatic affirmance penalty on the appellant. The court refused to apply the state penalty because Federal Rule of Appellate Procedure 38 addressed the same subject and controlled.
Respondents brought this tort action in Alabama state court to recover damages for injuries sustained in a motorcycle accident. Petitioner removed the case to a Federal District Court having diversity jurisdiction. A jury trial resulted in a judgment of $800,000 for respondent Alan Woods and $5,000 for respondent Cara Woods. Petitioner posted bond to stay the judgment pending appeal, and the Court of Appeals affirmed without modification. 768 F.2d 1287 (CA11 1985). Respondents then moved in the Court of Appeals, pursuant to Ala. Code § 12-22-72 (1986), for imposition of that State’s mandatory affirmance penalty of 10% of the amount of judgment. Petitioner challenged the application of this statute as violative of the equal protection and due process guarantees of the Fourteenth Amendment and as “a procedural rule . . . inapplicable in federal court under the doctrine of Erie Railroad Co. v. Tompkins, 304 U. S. 64 (1938) and its progeny.” The Court of Appeals summarily granted respondents’ motion to assess the penalty and subsequently denied a petition for rehearing. The parties have stipulated that the final judgment has been paid, except for the $30,500 statutory affirmance penalty, which petitioner has withheld pending proceedings in this Court. The Supreme Court granted certiorari to consider the equal protection and due process challenges as well as the Erie claim. 475 U. S. 1080 (1986).
View caseHamid Hassan sued in federal court despite a contract clause selecting a state forum. A state rule would have enforced the clause strictly. The court applied 28 U.S.C. § 1404(a) instead because the federal statute was on point and valid under Hanna Part I.
Helena Hoffman prevailed in a diversity action and sought attorney fees under a federal statute. A state rule limited fee awards in similar cases. The court granted fees under the federal provision because it was valid and directly addressed the issue.
Hanna Part I requires application of the federal rule whenever a valid Federal Rule of Civil Procedure is directly on point. The rule must be at least arguably procedural and within the scope of the Rules Enabling Act. State law yields even if the outcome differs.
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Hanna Part I applies when a Federal Rule of Civil Procedure is on point and valid. The forum-shopping test applies only when no federal directive governs the issue. The two inquiries are sequential.
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No. If the federal rule would abridge, enlarge, or modify a substantive right, it falls outside the Rules Enabling Act and Hanna Part I does not authorize its application. The rule must remain procedural in character.
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…we reverse the decision of the Court of Appeals. The Rules Enabling Act, 28 U. S. C. § 2072 (1958 ed.), provides, in pertinent part: "The Supreme Court shall have the power to prescribe, by general rules, the forms of process, writs, pleadings, and motions, and the practice and procedure of the district courts of the…