Erie Railroad Co. v. Tompkins

Brief Fact Summary.

Tomkins (a Pennsylvania citizen) sued Erie Railroad Co. (a New York company) in federal district court in New York for negligence, seeking to recover for injuries he sustained when he was injured by one of Erie’s passing trains. The trial judge refused to rule that Pennsylvania law applied to preclude recovery. A jury verdict was entered for Tompkins; the Court of Appeals affirmed. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

A federal district court sitting in diversity applies state statutory and common law.

Facts.

Tomkins (a Pennsylvania citizen) was injured in Pennsylvania by a passing freight train while he was walking along a right of way at night. He sued Erie Railroad Co. (a New York company), operator of the rain, in federal district court in New York to recover for the injuries he sustained, based on alleged negligence.  The trial judge refused to rule that Pennsylvania common law applied, under which Tomkins’ recovery would allegedly have been precluded.  A jury verdict was entered for Tompkins. The Court of Appeals affirmed. The Supreme Court granted certiorari to determine whether the court was free to disregard the alleged rule of Pennsylvania common law.

Issue.

Did the district court err in disregarding the alleged rule of Pennsylvania common law?

Held.

Yes. Except for matters governed by the federal Constitution or federal statutes, a federal district court must apply state statutory and common law .

Concurrence.

Justice Reed

The concurring decision agreed that following state laws in diversity cases should mean following state statutory and common law, and agreed with the majority’s decision except to the extent that the majority characterized the prior course of law, from which it was now diverting, as unconstitutional.

Discussion.

Prior law (Swift v. Tyson) allowed federal courts in diversity cases to exercise “independent judgment” in matters of general jurisprudence, but this prior rule led to “political and social defects” and not to the benefits anticipated. Therefore, in matters other than those governed by the federal Constitution or acts of Congress, state law, both statutory and common law, should be applied.