Hanna v. Plumer

Citation. 380 U.S. 460 (1965)

Brief Fact Summary.

Petitioner sued Respondent in federal court through diversity jurisdiction and served Respondent according to federal rules instead of state rules. Respondent moved for summary 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 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 Rule of Civil Procedure 4(d)(1)?

Held.

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

Concurrence.

Justice Harlan

Justice Harlan agreed with the outcome but argued that the Court oversimplified the purpose of Erie Railroad Co. v. Tompkins by listing only two aims. Whereas the outcome determinative test from Guaranty Trust Co. v. York favors state law, the Court’s opinion favors federal law. He argued instead in favor of a middle ground.

Discussion.

The Court rejected the Respondent’s argument that precedent set in Erie Railroad Co. v. Tompkins and Guaranty Trust Co. v. York prevented the application of Rule 4(d)(1). Instead, the Court clarified that the outcome determinative test must be considered in conjunction with the twin aims of Erie Railroad Co. v. Tompkins: to discourage forum shopping and the inequitable administration of law. Here, application of Rule 4(d)(1) would not trigger either concern because its application did not sufficiently alter the enforcement of a substantial state right. The Court further clarified that the Federal Rules of Civil Procedure fall within the power of Congress to govern the practice and pleadings of federal courts.