Brief Fact Summary.
There was a car crash and Plaintiff sued Defendant, the executor of the decedent driver’s estate. Plaintiff brings case in federal court in Massachusetts. Plaintiff served Defendant through substituted service of process which was okay under FRCP 4 but not under Massachusetts law.
Synopsis of Rule of Law.
If a plaintiff serves a defendant properly under the FRCP the plaintiff can proceed with a state law claim that requires a different method of service for establishing liability.
Not only are nonsubstantial, or trivial, variations not likely to raise the sort of equal protection problems which troubled the Court in Erie; they are also unlikely to influence the choice of a forum.View Full Point of Law
There was a car crash that resulted in the death of the negligent driver. Plaintiff Hanna, the surviving driver, brough suit in federal court based on diversity jurisdiction. Plaintiff served Defendant, executor of decedent driver’s estate, following FRCP 4. But, since Defendant Plumer was away, Plaintiff gave the paperwork to Defendant Plumer’s wife. Under Massachusetts law however, this substituted service of process that was okay under FRCP 4 was not allowed. The Massachusetts law required the executor to be served personally in order to be liable. As a result of this defect, Defendant Plumer moved for summary judgement based on an affirmative defense allowed under Massachusetts law that allowed dismissal for deficient service. The district judge dismissed the case, First Circuit Court of Appeals affirmed, and the Supreme Court of the United States granted certiorari.
Can a plaintiff bringing suit in federal court based on diversity jurisdiction serve the defendant under the federal rules and still proceed with a state law claim that requires a different method of service?
Yes, a plaintiff bringing suit in federal court based on diversity jurisdiction can serve the defendant under the federal rules and still proceed with a state law claim that requires a different method of service. The judgement of the court of appeals is reversed and Plaintiff Hanna is permitted to continue with her lawsuit.
Justice Justice Harlan concurring
Erie represents respect for state laws, and the court’s test here, while the outcome is correct, may damage state laws in order to save irrelevant federal procedural rules.