Brief Fact Summary.
A Pennsylvania man is injured by a New York railroad company while walking along train tracks. Plaintiff believes federal law should apply because it would require Defendant to have higher duty of care, while the Defendant thinks Pennsylvania law should apply because it would lower their duty to Plaintiff and help their case.
Synopsis of Rule of Law.
A federal court sitting in diversity must apply state substantive law, whether statutory or common law.
Under the Rules of Decision Act, the laws of the several states, except where the Constitution or the 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.View Full Point of Law
Plaintiff Tompkins, a citizen of Pennsylvania, was injured by a train operated by Defendant Erie, a New York company while walking along train tracks. Plaintiff Tompkins sued Defendant Erie in New York federal court. Defendant Erie argued that the company was not liable under Pennsylvania state law because Plaintiff Tompkins was a trespasser and they would only be liable if their actions were wantonly negligent. Plaintiff Tompkins argued that federal general law should apply. The trial judge relied on Swift v. Tyson in holding that federal courts are only bound to apply state statutory and customary law but not common law, and therefore federal general law applied. The majority rule under federal law was that railroad companies like Defendant Erie owed a duty of ordinary care to travelers like Plaintiff Tompkins, therefore the district court entered judgement for Plaintiff Tompkins. The court of appeals affirmed, holding that federal courts could use their discretion on matters of general law. The Supreme Court of the United States granted certiorari.
Must a federal court sitting in diversity apply state common law?
Yes, a federal court sitting in diversity must apply state common law. The holding below is reversed.
Justice Justice Cardozo did not participate in the consideration or decision.
Justice Cardozo did not participate in the consideration or decision.