Walker v. Armco Steel Corp.

Brief Fact Summary.

Walker brought an action against Armco Steel Co. in federal district court in Oklahoma. The district court dismissed the complaint, concluding that it was barred because it was untimely under the Oklahoma statute of limitations, based on Oklahoma state law dictating when an action is commenced. The court of appeals affirmed. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

Where there is no direct conflict between a state law and a federal rule, and in the absence of a federal rule directly on point, state service requirements which are an integral part of state statutes of limitations should control in an action based on state law filed in federal court based on diversity jurisdiction.

Facts.

Walker brought an action against Armco Steel Co. in federal district court in Oklahoma. The district court dismissed the complaint, concluding that it was barred because it was untimely under the Oklahoma statute of limitations because of when the action was commenced under state law. The court of appeals affirmed, finding that there was a direct conflict between the state statute’s rule regarding commencement of actions and the federal rule (Federal Rule of Civil Procedure 3), but concluding that it was constrained to follow precedent (Ragan v. Merchants Transfer & Warehouse Co.) which held that state law was applicable. The Supreme Court granted certiorari.

Issue.

Was the complaint in this case properly dismissed as barred in accordance with the state statute of limitations or did Federal Rule of Civil Procedure 3 apply to determine when an action is commenced for purposes of tolling the state of limitations?

Held.

The complaint was properly dismissed as barred under the state statute of limitations.

Discussion.

There was no direct conflict between the federal rule and state law; in the absence of a federal rule directly on point, state service requirements, which were an integral part of the state statute of limitations, should control in this action, where federal jurisdiction was based on diversity of citizenship. There was no reason why, in the absence of a controlling federal rule, an action based on state law that would be barred in the state courts because of the statute of limitations should be allowed to proceed in federal court solely because there is diversity of citizenship.