Hanna v. Plumer

Citation. 380 U.S. 460. 85 S.Ct. 1136, 14 L.Ed.2d 8 (1965)

Brief Fact Summary.

Hanna (Plaintiff) sued Osgood’s estate (Defendant) in federal court through diversity jurisdiction and served Defendant according to federal rules instead of state rules. Defendant moved forsummary judgment.

Synopsis of Rule of Law.

A federal court ruling over a case under diversity jurisdiction must apply applicable Federal Rules of Civil Procedure, unless their application would encourage forum shopping or the inequitable administration of law.

Facts.

Hanna (Petitioner), a citizen of Ohio, suffered injuries in a car accident in Massachusetts allegedly caused by Louise Plumer Osgood, a Massachusetts citizen. Petitioner sued Osgood’s estate (Respondent) in the District Court for the District of Massachusetts under federal diversity jurisdiction. The Respondent moved for summary judgment because the Petitioner served the Respondent pursuant to the requirements of Federal Rules of Civil Procedure, Rule 4(d)(1) instead of Massachusetts law.

Issue.

In a civil case, brought into federal court under diversity jurisdiction, should the court rely on the state’s service of process law instead of Federal Rules of Civil Procedure, Rule 4(d)(1)?

Held.

No, the court should apply the Federal Rules of Civil Procedure, Rule 4(d)(1). The case is reversed.

Concurrence.

Justice Harlan

Justice Harlan believes the Court has oversimplified the Erie doctrine by listing only two aims. Whereas the outcome determinative test favors state law, the Court’s opinion favors federal law. He argues for middle ground.

Discussion.

The Court rejects the Respondent’s arguments that Rule 4(d)(1) cannot be applied because of the outcome determinative test. The Court narrows the applicability of the outcome determinative test to instances where the twin aims of the Erie doctrine are triggered: forum shopping or the inequitable administration of law. Here, application of Rule 4(d)(1) would not trigger either aim because its application does not sufficiently alter the enforcement of a substantial state right. The Court further clarifies that the Federal Rules of Civil Procedure fall within the power of Congress to govern the practice and pleadings of federal courts, meaning the Erie doctrine doesn’t apply anyway.