Erie Railroad Co. v. Tompkins

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Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), is a landmark decision of the Supreme Court of the United States which held that the United States does not have a general federal common law and that U.S. federal courts must apply state law, not federal law, to any lawsuit between parties from different states that does not involve federal questions . The Court's decision overturned nearly a century of case law on federal civil procedure and established the foundation of the modern law of diversity jurisdiction .

Although Erie is not widely known among non-experts, most American legal scholars and lawyers regard it as one of the most important decisions in U.S. Supreme Court history.

The decision "goes to the heart" of the American system of federalism and the relationship between the U.S. federal government and the states .

Contents

• 1 Legal background

• 2 Case history

• 3 Supreme Court decision

  • 3.1 Opinion of the Court

  • 3.2 Reed's concurrence in the judgment

  • 3.3 Butler's dissent

• 4 Aftermath

• 5 Subsequent jurisprudence

• 6 See also

• 7 References

  • 7.1 Footnotes

  • 7.2 Citations

  • 7.3 Works cited

• 8 External links

Legal background

(https://en.wikipedia.org/w/index.php?title=Erie_Railroad_Co._v._Tompkins&action=edit&section=1 "Edit section: Legal background")

Under the traditional view of the United States's system of federalism, each U.S. state is a sovereign polity in all aspects other than those the U.S. Constitution commits to the federal government, which has supremacy over the states in those areas. Consequently, each U.S. state has its own courts and legal system governing areas such as property law , contract law , tort law , commercial law , criminal law , and family law . Due to the United States's historical origins in the British Empire , all U.S. states except Louisiana have inherited or adopted the English common law for their legal systems.

Shortly after the Constitution's ratification, Congress passed the Judiciary Act of 1789 , which created the U.S. federal court system underneath the U.S. Supreme Court. The Act gave U.S. federal courts diversity jurisdiction , allowing them to hear lawsuits between citizens of different states involving disputes over substantial sums of money, even when no questions of federal law are involved. Section 34 of the Judiciary Act—known as the Rules of Decision Act —provided that federal courts would apply state laws when adjudicating lawsuits between citizens of different states.

The laws of the several states, except where the Constitution or treaties of the United States or Acts of Congress otherwise require or provide, shall be regarded as rules of decision in civil actions in the courts of the United States, in cases where they apply.

— Judiciary Act of 1789, section 34 ("Rules of Decision Act") (28 U.S.C.  § 1652 ).

Interpreting the meaning of this statute has been one of the most difficult legal issues in American federal jurisprudence. It provides that U.S. federal courts shall apply state law when hearing cases under diversity jurisdiction. It does not specify, however, whether the phrase "the laws of the several States" means only statutes passed by a state's legislature , or whether it also includes the common law decisions of a state's supreme court .

The U.S. Supreme Court addressed the question in its 1842 decision _Swift v. Tyson _. In Swift, the Court ruled that the Rules of Decision Act's phrase "laws of the several States" referred only to each state's statutory laws passed by their legislatures, and did not include each state supreme court's interpretation and construction of the English common law. The Court concluded that this allowed U.S. federal courts to create a general American "federal common law " for federal courts that would cover areas such as commercial law. But applying the Court's holding in Swift proved difficult, and American lawyers, judges, and legal scholars became increasingly opposed to it during the late 19th and early 20th centuries.

Case history

(https://en.wikipedia.org/w/index.php?title=Erie_Railroad_Co._v._Tompkins&action=edit&section=2 "Edit section: Case history")

The incident location, as viewed in 1937 and 2024.

The Erie case involved an incident that took place in the early hours of July 27, 1934, in Hughestown, Pennsylvania . Local resident Harry Tompkins was walking home in the darkness on a pathway that ran alongside a railroad track . An oncoming train approached and, as it passed, an object protruding from one of the train cars—said to be an unlatched door—hit Tompkins and knocked him to the ground. He landed on the railroad tracks, and the train's wheels crushed his right arm beyond repair. An ambulance took him to a local hospital, where doctors amputated most of his arm.

The train that hit Tompkins was owned and operated by the Erie Railroad Company . After he recovered, Tompkins sued the company for negligence . Because Tompkins resided in Pennsylvania and Erie Railroad was incorporated in New York , Tompkins invoked

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