Aug 08, 2011 · Under Pennsylvania common law, Harry Tompkins of Hughestown lost his case against the Erie Railroad, a New York State company. Tompkins had been struck by an unsecured door of a passing train and severely injured near this spot on July 27, 1934. In a landmark decision, the U.S. Supreme Court ruled in 1938 that, in cases between citizens of ...
Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), was a landmark decision of the U.S. Supreme Court in which the Court held that that there is no general American federal common law and that U.S. federal courts must apply state law, not federal law, to lawsuits between parties from different states that involve no federal questions.In reaching this holding, the Court overturned …
3. The Erie insisted that its duty to Tompkins was no greater than that owed to a trespasser. It contended, among other things, that its duty to Tompkins, and hence its liability, should be determined in accordance with the Pennsylvania law; that under the law of Pennsylvania, as declared by its highest court, persons who use pathways along the railroad right of way—that …
Citation304 U.S. 64 Brief Fact Summary. Defendant Harry Tompkins, was injured by a freight car of Plaintiff Erie Railroad while in Hughestown, Pennsylvania. Defendant brought suit in federal district court in New York, asking the judge to apply “general law” regarding negligence, rather than Pennsylvania law, which required a greater degree of negligence.
justice Louis BrandeisFor the purposes of the decision's core holding, six justices formed the majority and joined an opinion written by justice Louis Brandeis.
A federal court jury awarded Tompkins damages. The 1842 Supreme Court decision in Swift v. Tyson ruled that federal courts sitting in diversity jurisdiction should apply federal common law to non-statutory causes of action.
The Swift decision was changed by the Supreme Court ruling in the case of Erie Railroad v. Tompkins, 304 U.S. 64 (1938) , which spawned the Erie doctrine.
directly on point, a federal court, including the Eighth Circuit, must make what is informally referred to as an "Erie guess." An "Erie guess" is an attempt to predict what a state's highest court would decide if it were to address the issue itself.
Erie's large repair facility in Hornell were closed when Conrail took over in 1976 and operations were consolidated at the Lackawanna's Scranton facility. However, the merged railroad only survived for 16 years before continued decline forced it to join Conrail in 1976....Erie Railroad: 1895–1960.YearTraffic196087893 more rows
The Erie doctrine is a fundamental legal doctrine of civil procedure in the United States which mandates that a federal court called upon to resolve a dispute not directly implicating a federal question (most commonly when sitting in diversity jurisdiction, but also when applying supplemental jurisdiction to claims ...
A “reverse-Erie” problem arises when a state court is hearing a federal cause of action and confronts a situation in which a state law and a federal law conflict. The term finds its etymological origin in Erie Railroad Co.Apr 30, 2014
Terms. Procedural law is the set of rules by which courts in the United States decide the outcomes of all criminal, civil, and administrative cases. Substantive law describes how people are expected to behave according to accepted social norms.Feb 3, 2022
“By legal tradition, most statutes of limitation are deemed procedural rather than substantive.” However, the federal court cited some Alabama Supreme Court cases where statute of limitations were deemed substantive.Jan 5, 2015
The test by which a federal court determines whether a state law must be followed if the outcome would be identical utilizing federal rules.
The Erie Doctrine is a binding principle where federal courts exercising diversity jurisdiction apply federal procedural law of the Federal Rules of Civil Procedure, but must also apply state substantive law. Pre-Erie Doctrine: The Erie Doctrine derives from the landmark 1938 U.S. Supreme Court case, Erie Railroad Co.
Thus, when a federal court asserts jurisdiction over pendent state law claims through the exercise of supplemental jurisdiction in a federal question case, courts regularly apply the Erie doctrine to resolve conflict between federal and state law.
Tyson,' as I understand it, is that the words 'the laws,' as used in section 34, line 1, of the Federal Judiciary Act of September 24, 1789, 28 U.S.C.A. § 725, do not included in their meaning 'the decisions of the local tribunals.'.
Tompkins denied that any such rule had been established by the decisions of the Pennsylvania courts; and contended that, since there was no statute of the state on the subject, the railroad's duty and liability is to be determined in federal courts as a matter of general law. 4.
On Monday I wrote about the legal legacy of Erie Railroad Company v Tompkins. Then last night on Legal History Blog I learned that in a forthcoming article, The Ballad of Harry James Tompkins, Brian Frye challenges the key factual assumptions at the heart of the Erie case.
On Monday I wrote about the legal legacy of Erie Railroad Company v Tompkins. Then last night on Legal History Blog I learned that in a forthcoming article, The Ballad of Harry James Tompkins, Brian Frye challenges the key factual assumptions at the heart of the Erie case.
This was probably because Tompkins had a stronger chance of success in New York than in Pennsylvania.
The path was narrow and close to the tracks but frequently used. Since it was late at night, the darkness prevented Tompkins from seeing an object that protruded from a passing train. He was struck by the object and fell under the train, where his arm was crushed.
Tompkins denied that any such rule had been established by the decisions of the Pennsylvania courts, and contended that, since there was no statute of the State on the subject, the railroad's duty and liability is to be determined in federal courts as a matter of general law.
Pierce Butler (Author) James Clark McReynolds. Ironically, Butler felt that Erie rather than Swift was a decision in which the Court had gone beyond its appropriate role. He pointed out that neither party had raised a constitutional question in the case, and thus the Court had decided it on inappropriate grounds.
A federal court exercising jurisdiction over such a case on the ground of diversity of citizenship, is not free to treat this question as one of so-called "general law," but must apply the state law as declared by the highest state court. Swift v. Tyson, 16 Pet. 1, overruled.
The Erie ruling significantly cut back the legal authority of federal judges in diversity jurisdiction cases. No longer could they create and apply a general common law at the federal level. Instead, federal judges must apply the state laws in which the federal court is located except when dealing with constitutional issues or matters specifically governed by acts of Congress. Federal courts in a sense became yet another level of state court in diversity cases not involving federal law.
Brandeis bluntly wrote, "There is no federal general common law." Referring to numerous legal studies critical of the Swift decision, Brandeis held that the Judiciary Act actually intended for federal courts to follow all laws of the state "unwritten as well as written," including those rules made by state courts. Brandeis contended that the Swift decision basically violated equal protection of the law since citizens could win some civil cases in a federal court that they could not have won in state courts. They could do this simply by moving to another state and filing the suit in a federal court as a diversity case. Corporations could even reestablish in a new state without actually moving. People or corporations could "shop around" for a federal court that would likely give the best ruling. As a result, plaintiffs (those filing a lawsuit) held a legal advantage over defendants (those the target of lawsuits). Brandeis noted that under the Swift rule, Tompkins' chances of winning an award depended on whether the railroad was a New York company or a Pennsylvania company, and that was not just. If Tompkins had filed suit in a Pennsylvania state court, he could not have received an award as he did from a federal court since the state court must follow the state rule. Brandeis also ruled that the Swift interpretation of the Judiciary Act was an unconstitutional invasion of state sovereignty. He wrote, the doctrine of federal general law "is an invasion of the authority of the state, and, to that extent, a denial of its independence."
The Erie Railroad Company, a corporation chartered (an ownership license) in New York state, operated a railroad in northeastern United States. Under law, Erie would be considered a New York "citizen." One day while Harry J. Tompkins, a Pennsylvania citizen, was walking on a footpath alongside Erie railroad tracks in Pennsylvania when he was struck and injured by an open boxcar door on a passing train. Tompkins filed a lawsuit in a Pennsylvania federal district court seeking compensation (money payment) for his personal injuries. He claimed Erie was negligent (careless) in operating the railroad. Because the case involved diversity of citizenship, a Pennsylvania resident and a New York corporation, he filed the suit in federal court.
When he fell to the ground, his right arm was crushed beneath the wheels of the train. Tompkins sued the railroad company in the United States District Court for the Southern District of New York. The district court, following the federal law, applied neither New York nor Pennsylvania common law, but instead applied federal common law, ...
A friend of Harry Tompkins had driven him to within a few blocks of his home, which was located on a dead-end street near the Erie Railroad's Erie and Wyoming Valley Railroad tracks in Hughestown, Pennsylvania. Tomkins was walking on a narrow but well-worn footpath adjacent to the tracks at 2:30 a.m. on July 27, 1934.
on July 27, 1934. A train approached in the darkness, and an object protruding from one of the cars struck Tompkins. When he fell to the ground, his right arm was crushed beneath the wheels of the train.
If so, the court may apply it as long as the statute that created it is constitutional and the statute itself is “on point,” or relevant to the issue the court is trying to resolve . A court that must apply state substantive law under the Erie Doctrine often finds that it’s facing a state law that is ambiguous, confusing, ...