Erie R. Co. v. Tompkins

Brief Fact Summary.

A citizen of Pennsylvania (Plaintiff) sued a citizen of New York (Defendant) in New York federal court for injuries sustained from a train in Pennsylvania. Defendant argued it was not liable for Plaintiff’s injuries based on Pennsylvania common law.

Synopsis of Rule of Law.

Applicable state statutory and common law is applied to a case in federal court under diversity jurisdiction unless the issue of the case falls under the U.S. Constitution or an act of Congress.

Facts.

Tompkins (Plaintiff), a citizen of Pennsylvania, was injured in Pennsylvania by a train while walking on the pathway next to the railroad track. Plaintiff sued the owner of the train, Erie Railroad Co. (Defendant), a citizen of New York, in the federal court for Southern New York under diversity jurisdiction. Defendant argued it was not liable for Plaintiff’s injuries based on Pennsylvania common law regarding liability for torts.

Issue.

In federal cases heard under diversity jurisdiction, where no federal statutory or constitutional law is at issue, should applicable state law be applied instead of federal common law?

Held.

Yes, the law of the state should be applied in these cases. The case was reversed and remanded.

Dissent.

Justice Butler

Butler argues that the Court’s decision inadvertently strikes down Section 34 as unconstitutional and creates nonuniformity among federal case decisions involving state common law.

Concurrence.

Justice Reed

Reed agrees that the Swift v. Tyson should be overturned, but disagrees that it should be overturned as unconstitutional.

Discussion.

The Court overturned Swift v. Tyson as unconstitutional because no federal general common law exists and the case gave federal judges too much discretion in the choice of law, encroaching on legitimate state power.