Also known as: Hanna · Hanna doctrine
Written by attorneys · grounded in primary & secondary sources — see below
A Supreme Court decision holding that a valid Federal Rule of Civil Procedure on point governs in a diversity action even when it conflicts with state practice, provided the federal rule is at least arguably procedural and consistent with the Rules Enabling Act. When no federal directive controls, state law applies if disregarding it would encourage forum shopping.
Hazel Hoffman filed a diversity breach-of-contract suit in federal court against Haven Medical. She served a jury demand fourteen days after the answer under Federal Rule of Civil Procedure 38. Haven Medical moved to strike the demand under a state statute requiring demands within seven days in medical-contract cases. The court applied the federal rule because it was on point and at least arguably procedural.
Heidi Henderson obtained a judgment against Horizon Dynamics in federal court. Horizon Dynamics appealed and lost. The court of appeals considered awarding damages under Federal Rule of Appellate Procedure 38 for a frivolous appeal. State law provided no such damages. The federal rule controlled the issue.
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Hamid Hassan won a large jury verdict against Helios Energy in a diversity tort case. Helios Energy moved for remittitur under a state statute setting a specific excessiveness standard. Federal appellate practice used a different abuse-of-discretion test. The court applied the federal standard to the review question.
Hana Hashimoto sued Highland Farms in federal court on state-law claims. The court dismissed the action with prejudice under Federal Rule of Civil Procedure 41(b) after the plaintiff failed to prosecute. A later state-court suit raised the same claims. The federal dismissal carried claim-preclusive effect under federal law.
Henry Harrison obtained a judgment against Hakeem Harris in state court. Harrison sought to garnish a debt owed to Harris by a third party located in another state. The garnishment proceeding raised questions of personal jurisdiction over the garnishee. Federal precedents on the issue supplied the governing analysis.
Horizon Dynamics engaged in bad-faith litigation conduct during a federal diversity case brought by Haven Medical. The district court imposed sanctions under its inherent authority rather than under any specific Federal Rule of Civil Procedure. State law limited such sanctions. The federal court retained power to sanction under its inherent authority.
A valid Federal Rule of Civil Procedure on point governs in diversity actions even if it conflicts with state practice, so long as the federal rule is at least arguably procedural and consistent with the Rules Enabling Act. State law controls only when no federal directive addresses the issue and disregarding the state rule would encourage forum shopping.
No. Once a valid Federal Rule of Civil Procedure is found to be on point and at least arguably procedural, it controls regardless of outcome-determinative effects or state policy preferences. The forum-shopping and inequitable-administration analysis applies only when no federal rule governs the issue.
Hanna v. Plumer confines the twin aims of Erie—discouraging forum shopping and avoiding inequitable administration of the laws—to situations lacking a controlling federal directive. When a Federal Rule of Civil Procedure is on point, the twin aims do not override the federal rule.
Hanna v. Plumer <!-- acedexams opinion md v1 -- Case information - Citation: 380 U.S. 460 (1965) Majority opinion Opinion of Chief Justice Warren The question to be decided is whether, in…