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Supreme Court of the United States - 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed.1188, 114 A.L.R. 1487, 304 U.S. 64, 82 L. Ed. 1188, 58 S. Ct. 817, 1938 U.S. LEXIS 984, SCDB 1937-170
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Case Summary
In the 1938 case Erie Railroad Co. v. Tompkins, Harry Tompkins sued Erie Railroad Co. for negligence after being injured by a train in Pennsylvania. Tompkins, a Pennsylvania citizen, filed the lawsuit in federal court due to differing citizenship with the New York-based defendant. The court found Erie Railroad negligent, applying the general common law from Swift v. Tyson (1842).
However, the Supreme Court overturned this decision, ruling that Pennsylvania law should have been applied, not general common law. Consequently, Swift v. Tyson was overruled, and the Court established that federal general common law does not exist. The Court emphasized that cases should apply the law from the state in which they arise, unless the Constitution or Congress dictates otherwise.
Erie Railroad Co. v. Tompkins is significant for changing the role of federal courts handling cases involving different states' citizens (known as diversity cases). The decision led to the creation of the Erie doctrine, which requires federal courts to apply state substantive law and federal procedural law in diversity cases. The case also emphasized state sovereignty and allowed for local variations in law. This ruling influenced the growth of legal realism and legal pluralism in American law.
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The Supreme Court ruled that federal courts can declare rules of decision in "general law" cases, but state law must be applied in all cases except those governed by the Federal Constitution or Acts of Congress. The common law enforced in a state is the law of that state, and the state's voice should have the final say. The Swift v. Tyson doctrine has been abandoned due to its unconstitutionality. The Court rejected the doctrine and reversed the Circuit Court of Appeals' judgment, which erred in ruling that the question of liability was one of general law. The Court interpreted the Judiciary Act of 1789, § 34, as allowing state laws to be considered as rules of decision in US court trials, but only for strictly local state laws and rights and titles to things with a permanent locality. The Court has generally followed applicable decisions of state courts, as long as they are consistent with the general law supported by reason and authority. The unconstitutionality of the rule of decision now condemned compels federal courts to follow decisions of state courts in matters of contracts and torts not positively governed by state enactments, rendering decisions of federal courts on these matters no longer authoritative.
The court has rejected the doctrine of Swift v. Tyson, which did not consider local tribunals' decisions as "the laws" in the Federal Judiciary Act of 1789. The court now believes that "laws" includes "decisions," rendering Swift v. Tyson invalid. The writer argues that Congress enacted legislation due to uncertainty about this issue in 1789, and federal power over procedure is well-established. The writer believes it is better to overturn an established construction of an Act of Congress than interpret the Constitution. Stare decisis is not an absolute requirement, and the writer disagrees with certain phrases in the opinion but does not elaborate on them.
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