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
CASE FACTS 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.
CONCLUSION 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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