Sunday, November 24, 2013

Erie Railroad Co. v. Tompkins case brief

Erie Railroad Co. v. Tompkins case brief summary
304 U.S. 64 (1938)


CASE SYNOPSIS
Petitioner railroad company appealed a decision of the United States Court of Appeals for the Second Circuit affirming judgment for respondent in a negligence action to recover damages for injuries respondent sustained when he was hit by a door projecting from petitioner's train while he was walking along a railroad right of way.

CASE FACTS
Respondent brought a negligence action against petitioner railroad company, seeking damages for injuries sustained when he was hit by a door projecting from petitioner's train while he was walking along a railroad right of way.

PROCEDURAL HISTORY
The circuit court affirmed the judgment in favor of respondent, refusing to consider petitioner's claim that it was not liable for respondent's injuries under state common law. It held instead that liability was a question of general law about which federal courts were free to render independent decisions.

DISCUSSION

  • On appeal, the court reversed and remanded, holding that there was no federal general common law, and that except in matters governed by the U.S. Constitution or by acts of Congress, the law to be applied by federal courts in any diversity case was the law of the state. 
  • In so holding, the court disapproved the contrary doctrine of Swift v. Tyson, 16 Pet. 1 (1842), finding it an unconstitutional assumption of powers by federal courts that invaded state autonomy and prevented uniformity in administering state law. 
  • The court also held that § 34 of the Federal Judiciary Act of 1789, 28 U.S.C.S. § 725, was not declarative of the Swift doctrine.
CONCLUSION
The judgment was reversed and the case remanded for consideration of applicable state law as to petitioner railroad company's liability for respondent's injuries, the court holding that there was no federal general common law, and that except in matters governed by the U.S. Constitution or by acts of Congress, the law to be applied by the federal courts in diversity cases was the law of the state.


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