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Hanna v. Plumer

    Brief Fact Summary. Plaintiff sued Defendant in federal court in Massachusetts based on diversity jurisdiction. Plaintiff served Defendant by mail pursuant to Rule 4(d)(1) of the Federal Rules of Civil Procedure. Defendant moved to quash the summons on the grounds that the Massachusetts service statute applied and it required personal service in order to be effective.

    Synopsis of Rule of Law. If the rule at issue is procedural and the federal rule is on point with the state rule, then the Federal Rule must be applied as long as it complies with the Rules Enabling Act, 28 U.S.C. Section: 2071 and the U.S. Constitution. If there is no federal rule on point, then the Erie doctrine should apply.

    Facts. Hanna (Plaintiff) and a citizen of Ohio sued Plumer (Defendant) and a citizen of Massachusetts in a federal court in Massachusetts. Defendant was executor of Osgood’s estate. Osgood was also a Massachusetts resident. Plaintiff alleged that she was involved in a car accident with Osgood in South Carolina. Service of process was made by leaving copies of the summons with Defendant’s wife, which complies with Federal Rule of Civil Procedure 4(d)(1). Defendant filed an answer stating that the action could not be maintained because it did not comply with Mass. General Laws Chapter 197, Sec. 9 which requires in hand delivery of the summons. The District Court granted summary judgment for Defendant after finding that the Massachusetts law was “outcome determinative.” The Court of Appeals affirmed the District Court’s judgment, ruling that the legislative purpose of the Massachusetts statute was to require personal notification within a year, which is a “substantive” matter.

    Issue. Should the District Court have applied Federal Rules of Civil Procedure 4(d)(1) instead of the state statute governing the method of process?

    Held. Yes.
    Under Guaranty Trust Co. v. York, 326 U.S. 99, 65 S.Ct. 1464, 89 L.Ed. 2079 (1945), whether the state or federal law is to be applied is not just whether the law is substantive or procedural, or whether it is outcome determinative, but whether it complies with the policies underlying the Erie doctrine.

    Rule 4(d)(1) is not prohibited by the Constitution. It is authorized by Article III and the Necessary and Proper Clause. The purpose of the Federal Rules is to create uniformity. The Erie doctrine and the extensions in York and Ragan v. Merchants Transfer & Warehouse Co., 337 U.S. 530, 69 S.Ct. 1233, 93 L.Ed. 1520 (1949), were not meant to block the federal rules if they are “outcome determinative” or have “integral relations.”

    Congress created the Federal Rules to create uniformity in the federal court system.

    Service of process is not a substantive right intended to be enforced by the Erie decision because the method of service here only “altered the mode of enforcing state-created rights” rather than changing the actual rights.

    Concurrence. Justice Harlan: The Court should focus on whether the rule applies to a situation that is normally one left to state regulation.

    Discussion. The majority opinion illustrates that the federal interest in creating a uniform code of procedure for the federal court system is secondary to the state’s procedural laws. In the event there is a direct conflict, the federal law must prevail so long as it complies with the Rules Enabling Act and the U.S. Constitution.


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