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Walker v. Armco Steel Corp.

    Brief Fact Summary
    Walker (Plaintiff) argued that, in a diversity action, Federal Rule of Civil Procedure 3 prevailed over a state law governing when, for statute of limitation purposes, an action is commenced.

    Synopsis of Rule of Law
    In a diversity action, state law regarding when an action is commenced prevails over Federal Rule of Civil Procedure 3.

    Facts
    Walker (Plaintiff) filed a personal injury action against Armco Steel Corp. (Defendant) in federal district court in Oklahoma, basing jurisdiction on diversity.  The complaint had been filed less than two years after the cause of action arose but was served well after this period passed.  Under the Oklahoma statute of limitations, an action was not considered “commenced†against a defendant until service was effected.  The district court rejected Plaintiff’s argument that Federal Rule of Civil Procedure 3, which provided that commencement of an action occurred upon filing, was applicable and dismissed the action under Oklahoma’s two-year statute of limitations.  The Tenth Circuit affirmed, and the Supreme Court granted review.

    Issue
    In a diversity action, does state law regarding when an action is commenced prevail over Federal Rule of Civil Procedure 3?

    Held
    (Marshall, J.)  Yes.  In a diversity action, state law regarding when an action is commenced prevails over Federal Rule of Civil Procedure 3.  Some time ago, this Court held that the statute of limitations in an action is a matter of substantive law, which federal courts are bound to follow in a diversity case.  Anything that would tend to toll or extend the statute must be considered likewise a matter of substantive law, and state law must prevail in that situation.  This would appear to decide the issue in this case.  However, Walker (Plaintiff) argued that, when a provision of the Federal Rules of Civil Procedure conflicts with a state rule, the federal rule must apply.  This is only true when the scope of the federal rule is broad enough to truly conflict with state rules.  There is no indication that Federal Rule of Civil Procedure 3 was meant to deal with the statute of limitations.  Instead, it simply sets the point from which the various timing requirements of the Federal Rules of Civil Procedure begin to run.  Since there is no existing conflict between Oklahoma’s rule and the Federal Rules, the Oklahoma rule prevails.  Affirmed.

    Discussion
    Conflicts law often involves the recognition of conflict more than the resolution of conflict.  In general, when a state rule conflicts with a federal rule in a diversity action, the federal rule prevails.  As demonstrated in this case, the challenge is often recognizing whether a conflict indeed exists.  In this case, it did not.


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