Master In a diversity case, Rule 3 does not toll a state statute of limitations; state law governs when an action is commenced for limitations purposes absent a direct conflict with a Federal Rule. with this comprehensive case brief.
Walker v. Armco Steel Corp. is a cornerstone Erie doctrine case clarifying the interplay between Federal Rule of Civil Procedure 3 and state statutes that tie tolling of the limitations period to service of process. The Supreme Court held that in diversity cases, when a state’s statute of limitations scheme treats service as integral to commencing an action, state law governs whether the limitations period is tolled. Rule 3’s statement that a civil action is commenced by filing a complaint does not displace state tolling rules because there is no direct conflict between the Federal Rule and state law.
The decision solidifies the Hanna framework: first ask whether a Federal Rule and state law directly collide; if not, Erie principles and the twin aims—discouraging forum shopping and avoiding inequitable administration of the laws—control. Walker reaffirms Ragan v. Merchants Transfer, distinguishing Hanna v. Plumer, and teaches litigants that filing on the last day in federal court will not save a claim if state law requires timely service to toll the statute.
446 U.S. 740 (U.S. 1980)
Plaintiff Walker, injured by an allegedly defective nail manufactured by Armco Steel, brought a personal-injury action in the U.S. District Court for the Western District of Oklahoma under diversity jurisdiction. Oklahoma provides a two-year statute of limitations for such claims and a commencement/tolling statute (12 Okla. Stat. § 97) that ties tolling to service of process, not mere filing. Under § 97, an action is deemed commenced for limitations purposes when the summons is served; a filing within the limitations period will relate back to the filing date only if service is accomplished within 60 days (or within the period of publication service). Walker filed his complaint in federal court just before the two-year limitations period expired, but he did not serve Armco until after the limitations period had run and beyond the state’s 60-day relation-back window. The district court dismissed the case as time-barred under Oklahoma law, and the Tenth Circuit affirmed.
In a diversity action, does Federal Rule of Civil Procedure 3—which provides that a civil action is commenced by filing a complaint—govern the tolling of a state statute of limitations, or does state law control when an action is deemed commenced for limitations purposes?
In diversity cases, absent a direct conflict between a valid Federal Rule of Civil Procedure and a state law, Erie and Hanna require application of state law that is integral to the statute of limitations. Federal Rule of Civil Procedure 3 defines commencement only for purposes of the Federal Rules; it does not toll a state statute of limitations. Accordingly, where state law makes service of process a prerequisite to tolling or to commencement for limitations purposes, that state rule governs in federal court.
State law controls. There is no direct conflict between Rule 3 and Oklahoma’s tolling/commencement statute; Rule 3 does not purport to toll state limitations periods. Because Walker failed to effect service within the time required by Oklahoma law, his action was not timely commenced for limitations purposes and is barred. Judgment affirmed.
The Court applied the Hanna framework. Step one asks whether a Federal Rule and a state rule directly collide. Interpreting Rule 3 in light of its text, structure, and history, the Court concluded that Rule 3 specifies when an action is considered commenced for purposes of the Federal Rules themselves (e.g., triggering deadlines for responsive pleadings, Rule 4 service periods, relation-back under Rule 15, and other rule-based time computations), but it does not address tolling of state statutes of limitations. Because Rule 3 can function alongside a state rule that conditions tolling on service, there is no direct collision. With no direct conflict, Erie principles control. Oklahoma’s statute makes timely service an integral part of its statute of limitations scheme: filing alone is an “attempt” to commence, and tolling relates back to filing only if service is made within 60 days; otherwise, the action is deemed commenced when service is effected. Treating this service component as inapplicable in federal court would encourage forum shopping and yield inequitable administration of the laws by allowing plaintiffs to avoid state time bars simply by filing in federal court. The Court reaffirmed Ragan v. Merchants Transfer, which had reached the same result pre-Hanna, and distinguished Hanna v. Plumer, where there was a direct collision between Federal Rule 4’s service method and a conflicting state service method, and the Federal Rule controlled. Here, by contrast, Rule 3 does not purport to replace the state’s tolling/commencement rule. The Rules Enabling Act also supports this reading because giving Rule 3 tolling effect would abridge or modify state substantive policies embedded in limitations schemes. Consequently, Oklahoma’s service-based tolling rule governs, rendering Walker’s suit untimely.
Walker is essential for understanding the Erie/Hanna analysis. It teaches that: (1) courts must first determine whether a Federal Rule and state law directly collide; (2) if not, state law applies when it is bound up with substantive rights, including limitations and tolling; and (3) Rule 3 does not toll state statutes of limitations in diversity cases. Practically, plaintiffs cannot rely on federal filing alone to preserve claims when state law conditions tolling on service; they must comply with the state’s service-related tolling rules even in federal court.
Hanna controls when there is a direct collision between a Federal Rule and a state rule and the Federal Rule is valid under the Rules Enabling Act; in that situation, the Federal Rule governs. Walker found no direct collision: Rule 3 regulates commencement for purposes of the Federal Rules, not tolling of state limitations. Thus Erie’s twin aims dictated applying state law. Walker distinguishes Hanna by limiting Rule 3’s scope to avoid a collision.
No. The Court reaffirmed Ragan’s core holding: in diversity cases, state rules that make service part of the statute of limitations must be applied in federal court. Walker harmonized Ragan with Hanna by explaining that Rule 3 does not directly conflict with state tolling rules, so Erie—not a Federal Rule—controls.
Rule 3 does not toll state statutes of limitations in diversity cases. It may mark commencement for federal procedural purposes (e.g., deadlines under the Federal Rules) and, in cases governed by federal limitations schemes (such as certain federal-question claims where Congress ties tolling to filing), the applicable federal statute or doctrine may give filing tolling effect. But Rule 3, standing alone, does not.
Then filing in federal court will toll the limitations period because the federal court applies the state’s tolling rule. Walker requires applying the state’s integrated limitations scheme, whether it ties tolling to filing or to service.
Rule 4(m) sets a federal deadline (typically 90 days) for serving process, but it does not displace state rules that make timely service a prerequisite to tolling. A plaintiff might satisfy Rule 4(m) yet still be time-barred if state law requires service within a shorter period to toll the statute. Plaintiffs must comply with both: meet state service-based tolling requirements to avoid a time bar and Rule 4(m) to avoid dismissal for failure to serve.
Walker v. Armco Steel underscores that the Erie doctrine is not merely theoretical; it shapes outcomes. The decision confirms that Rule 3 does not toll state statutes of limitations, and that state service-based commencement rules govern in diversity cases absent a direct conflict with a Federal Rule. By reaffirming Ragan and harmonizing it with Hanna, the Court provided a clear roadmap for lower courts confronting similar questions.
For practitioners and students, the case issues a practical warning: filing in federal court on the last day is risky in states that condition tolling on timely service. To preserve claims, comply with the state’s tolling/commencement requirements in addition to the Federal Rules, and analyze potential conflicts through the Hanna two-step before assuming a Federal Rule controls.