Erie Railroad Co. v. Tompkins [1938]

304 U.S. 64 (1938) · Supreme Court of the United States · United States

civil procedurecivil procedurefederal courts law

Issue

May a federal court sitting in diversity apply federal general common law?

Held

No. Federal courts apply state substantive law in diversity cases.

Exam use

Review the ratio and reasoning before applying this case in problem questions.

Summary

Foundational Erie doctrine decision.

Facts

A Pennsylvania plaintiff sued a railroad in federal diversity jurisdiction after an accident.

Issue

May a federal court sitting in diversity apply federal general common law?

Held

No. Federal courts apply state substantive law in diversity cases.

Ratio Decidendi

In diversity jurisdiction, federal courts apply state substantive law and federal procedural law.

Reasoning

There is no federal general common law, and prior doctrine encouraged inequitable forum shopping.

Essay-Ready Explanation Generator

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Reference to Erie Railroad Co. v. Tompkins (304 U.S. 64 (1938)) strengthens a civil procedure answer because the case reflects the principle that In diversity jurisdiction, federal courts apply state substantive law and federal procedural law. Applied to a problem question, the case should be used after identifying the issue as May a federal court sitting in diversity apply federal general common law? The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.

Significance

Foundational Erie doctrine decision.

Related Cases

No related cases listed.

Exam Tips

Review the ratio and reasoning before applying this case in problem questions.

Revision Checklist

  • Name the issue before discussing facts so the marker sees the legal question immediately.
  • State the holding in one sentence, then use the ratio to explain why the court reached that result.
  • Use the citation and jurisdiction to show why this authority matters for the problem you are answering.
  • Pair this case with one supporting or contrasting authority if the question tests limits, policy, or exceptions.

Sources