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The Erie Railroad v. Tompkins case brief examines this foundational Supreme Court decision that established the Erie doctrine and transformed federal-state law relationships in federal courts. This landmark civil procedure case is essential for law students studying federalism and the role of federal courts.
Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938)
Harry Tompkins, a Pennsylvania resident, was walking along railroad tracks in Pennsylvania when he was struck by a train operated by Erie Railroad, a New York corporation. Tompkins sued Erie in federal court in New York, claiming diversity jurisdiction. Under Pennsylvania state law, Tompkins would likely be considered a trespasser with limited rights to recovery. However, under federal common law as established in Swift v. Tyson, Tompkins could potentially recover as the railroad owed a duty of care to anyone on the tracks.
In diversity cases, should federal courts apply federal common law or state law when determining substantive legal rights?
Federal courts sitting in diversity must apply state substantive law, including state common law, as determined by the state's highest court. There is no federal general common law. Federal courts may only apply federal law when authorized by the Constitution or federal statute.
The Court held that federal courts must apply Pennsylvania state law to determine Tompkins' rights. The Court overruled Swift v. Tyson and established that federal courts have no power to create general federal common law in diversity cases.
Justice Brandeis reasoned that Swift v. Tyson was unconstitutional because it allowed federal courts to ignore state law without constitutional authority. The Constitution does not grant federal courts power to create general common law. Allowing federal courts to apply different law than state courts violated principles of federalism and equal protection, creating forum shopping and discrimination against local citizens who could only sue in state court.
Erie established the fundamental principle that federal courts are courts of limited jurisdiction that cannot create general common law. It eliminated the dual system of law that existed under Swift v. Tyson, reduced forum shopping, and reinforced federalism principles. The decision continues to shape federal court practice and the relationship between federal and state law.
Erie Railroad v. Tompkins is crucial for law students because it established the fundamental principle governing federal-state law relationships in diversity cases. The case is essential for understanding civil procedure, federalism, and the proper role of federal courts, making it one of the most important cases in federal court practice.
The key rule from Erie Railroad v. Tompkins established that federal courts sitting in diversity must apply state substantive law, including state common law. Federal courts cannot create general federal common law and must follow state law as determined by the state's highest court, eliminating the dual system of law that existed under Swift v. Tyson.
Professors use Erie Railroad v. Tompkins to teach civil procedure, federalism, and the Erie doctrine. The case is often used to discuss federal court jurisdiction, the substance-procedure distinction, forum shopping, and the complex relationship between federal and state law in our federal system.
Erie Railroad v. Tompkins fundamentally transformed federal court practice by establishing that federal courts are courts of limited jurisdiction that must respect state law in diversity cases. Understanding this case is crucial for law students studying civil procedure and federal courts, as it continues to influence litigation strategy and the complex relationship between federal and state law.