Friday, December 6, 2013

Ferens v. John Deere Co. case brief

Ferens v. John Deere Co. case brief summary
494 U.S. 516 (1990)

Plaintiff farmer filed a petition for a writ of certiorari to the United States Court of Appeals for the Third Circuit to challenge its decision to affirm a district court's judgment to dismiss plaintiff's tort action against defendant manufacturer. The appellate court held that after plaintiff transferred the action from a Mississippi federal court to a Pennsylvania federal court, the tort action was time-barred under Pennsylvania law.

Plaintiff farmer was injured in an accident with a combine harvester. Plaintiff brought an action in a Pennsylvania federal court against defendant manufacturer, raising contract and warranty claims, and an action in a Mississippi federal court, based on diversity jurisdiction, alleging negligence and products liability. The tort action was not barred under Mississippi law. Plaintiff then filed an action under 28 U.S.C.S. § 1404(a) to transfer the Mississippi action to the Pennsylvania federal court as a more convenient forum. The motion was granted, but the district court dismissed the tort action after invoking the Pennsylvania two-year statute of limitations period. The appellate court affirmed, holding that a transferor court's choice-of-law rules did not apply after a transfer under § 1404(a).


  • On a writ of certiorari, the Court reversed, holding that the Mississippi statute of limitation governed the action. 
  • The Court found that § 1404(a) did not deprive parties of state-law advantages that existed absent diversity jurisdiction. 
  • The Court noted that the decision to transfer venue under § 1404(a) turned on considerations of convenience and the interest of justice.

The Court reversed the appellate court's affirmance of the district court's dismissal of plaintiff farmer's tort action against defendant manufacturer. The Court held that Mississippi choice-of-law applied even after the action was transferred from a Mississippi federal court to a Pennsylvania federal court. Thus, the action was not time-barred by Pennsylvania's two-year statute of limitation.

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