Burlington Northern Railroad Co. v. Woods

Brief Fact Summary.

Woods brought a personal injury action against Burlington Northern Railroad Co. in federal court. Jurisdiction was based on diversity of citizenship. Judgment was entered for Woods. Burlington appealed. The Court of Appeals affirmed and also granted Woods’ request for imposition of a penalty against Burlington, which was imposed pursuant to a state statute that provided for a mandatory affirmance penalty.

Synopsis of Rule of Law.

Federal Rule of Appellate Procedure 38, which allows the court, at its discretion, to impose a penalty for a frivolous appeal, regulates matters of procedure; thus, it displaces a state rule that provides for a mandatory affirmance penalty.

Facts.

Woods brought a personal injury action against Burlington Northern Railroad Co. in federal district court in Alabama. Jurisdiction was based on diversity of citizenship. Judgment for over $300,000 was entered for Woods. Burlington appealed. The Court of Appeals affirmed and granted Woods’ request for imposition of a ten percent penalty under an Alabama’s statute that provided for a mandatory affirmance penalty of ten percent of the amount of the judgment.

Issue.

Was Alabama’s state mandatory affirmance penalty statute applicable?

Held.

No. Alabama’s statemandatory affirmance penalty statute conflicted with Federal Rule of Appellate Procedure 38, which allows the court, at its discretion, to impose a penalty for a frivolous appeal.

Discussion.

Federal Rule of Appellate Procedure 38, which provides authority for a court, at its discretion, to impose a penalty for a frivolous appeal, regulates procedural matters. Alabama’s affirmance penalty rule, which provides for mandatory imposition of a penalty, conflicted with the Federal Rule. The Federal Rule represented a valid exercise of Congress’s rulemaking authority, and supplanted the state rule.