Erie Railroad Co. v. Tompkins [1938]

304 U.S. 64 (1938) · Supreme Court of the United States · United States

Summary

Foundational Erie doctrine decision.

Facts

A Pennsylvania plaintiff sued a railroad in federal diversity jurisdiction after an accident.

Issue

May a federal court sitting in diversity apply federal general common law?

Held

No. Federal courts apply state substantive law in diversity cases.

Ratio Decidendi

In diversity jurisdiction, federal courts apply state substantive law and federal procedural law.

Reasoning

There is no federal general common law, and prior doctrine encouraged inequitable forum shopping.

Significance

Foundational Erie doctrine decision.

Related Cases

No related cases listed.

Exam Tips

Review the ratio and reasoning before applying this case in problem questions.

Sources