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Erie Doctrine Flow Chart (Hanna)
Transcript of Erie Doctrine Flow Chart (Hanna)
Before We Begin...
State laws as Rules of Decision: 28 U.S.C. 1652
The laws of the several States, except where the Constitution or treaties of the United States or Acts of Congress otherwise required or provide, shall be regarded as rules of decision in civil actions in the courts of the United States, in cases where they apply
Swift v. Tyson
Tyson bought land from people who led him to believe they owned the land...turns out they didnt
Perpetrators gave Tyson's money to Swift, who they owed money too.
NY law: "Pre-existing debt does not constitute valuable consideration..."
Tyson loses due to 1652.
Erie Railroad Co. v Tompkins
Tort Claim against Railroad
PA law: "persons who use pathways along the railroad right of way (longitudinal pathway as distinguished from a crossing) are deemed trespassers..."
1) Avoid inconsistant application of law
2) Prevent forum shopping
Holding: "Unless matter is governed by U.S. Const or Congress, state law is not matter of federal concern..."
Guaranty Trust v. York
Sweringen Bros. owed stockholders lots of money and made offer - notholders did not accept.
Statute of Limitations = Substantive Law or Procedural Law?
Outcome Determinative Test
Outcome in fed court should be same as if tried in state court.
Contractor seeks tort claim against employer
Contractor seeks jury trial
South Carolina tradition on adjudicating issues of immunity
State Practice over Policy
Byrd v. Blue Ridge, Inc.
Rules Enabling Act: 28 USC 2072
(a) The Supreme Court shall have the power to prescribe general rules of practice and procedure and rules of evidence for cases in the United States district courts (including proceedings before magistrate judges thereof) and courts of appeals.
(b) Such rules shall not abridge, enlarge or modify any substantive right. All laws in conflict with such rules shall be of no further force or effect afger such rules have taken effect.
Finally... HANNA v. Plumer
Hanna (OH) sues Plumer (MA) in Ma.
Hanna leaves copy of summons in compliance with Federal Rule 4(d)(1).
Plumer objects: service violated MA Gen. Laws Ch. 197 Sec. 9.
Outcome Determinative Test
Holding: Rule 4 does not abridge, enlarge, or modify any susbtantive right.
Is the Action Diverse?
We ask this question first because there is no need to conduct an Erie or Hanna analysis if the claim is a federal question.
If the answer is yes, continue to next bubble
Is there a Federal/State Rule or Statute on "Point"?
"On Point" - rule or statute is sufficiently broad to apply issue before court, creating conflict with competing state legal rule.
If yes to state, analysis is finished
If no to either, continue to Erie Analysis.
If no to state but yes to federal, continue to next Hanna bubble
Does Rule Comply with 2072?
If Statute is at issue, then no need for Rules Enabling Act Analysis. Assess Constitutionality
Go to next bubble
"Does rule/statute regulate the judicial process for enforcing rights and duties recognized by substantive law and for justly administering remedy and redress for disregard or infraction of them?"
If Rule doesn't abridge, enlarge, or modify any substantive rights, then we assess Constitutionality
If Rule does abridge...it is invalid and cannot be used, proceed with Erie analysis
If rule/statute regulates procedural matters, or may be classified as procedural and substantive, then applicable.
If rule/statute regulates only state substantive matters, then it cannot be enforced.