Warning
Info
- - tl;dr
- - ICRA
- - Facts & Holding
- - DeepDive
0 0
Supreme Court of the United States - 446 U.S. 740
Tags: Civil Procedure, Choice of Law
tl;dr:
When there is not a direct clash between federal and state procedural rules, the twin aims of Erie must be evaluated to determine which law governs.Video Summary
Case Summary
In the case Walker v. Armco Steel Corp. (1980), James Walker sued Armco Steel, an Ohio corporation, in federal court due to their diverse citizenship. Walker, an Oklahoma citizen, was injured by a falling steel rod from an Armco truck. He filed his complaint within Oklahoma's two-year statute of limitations but didn't serve Armco until over 60 days later. Armco argued for dismissal, claiming the statute of limitations had expired. They said that, under Oklahoma law, the action isn't deemed as started until the defendant is served (or within 60 days of complaint filing).
Walker countered that, per Federal Rule of Civil Procedure 3, the action starts upon complaint filing, regardless of service timing. The district and appeals courts dismissed the complaint, holding that Oklahoma law applied and the action was time-barred. The Supreme Court agreed, invoking the Erie doctrine, mandating federal courts to follow state substantive law in such cases. It differentiated this case from Hanna v. Plumer and maintained that Rule 3 only applies to federal rules.
By applying Oklahoma law, the Court reinforced the principle of federalism, preventing forum shopping and unfair legal administration. This case highlights the complex balance between enforcing state substantive law and federal procedural law and the interpretation of Rule 3 and state statutes of limitations in civil actions.
DeepDiveHighlight a legal term to see the definition
The Supreme Court held that in a diversity case, a federal court should follow state law in determining when an action is commenced for the purpose of tolling the state statute of limitations. The Court rejected the argument that Rule 3 of the Federal Rules of Civil Procedure governed the tolling of the state statute of limitations. The Court held that the service of summons statute was an integral part of the state statute of limitations, and under York, the statute of limitations was part of the state-law cause of action. Therefore, the Court could not give the cause of action longer life in federal court than it would have had in state court without adding something to the cause of action, which would be inconsistent with Erie R. Co. v. Tompkins. In a civil action based on diversity of citizenship, the Federal Rule 4(d)(1) governs the manner in which process is served, rather than state law, in the absence of a conflicting state procedure. The court in this case will not overrule Ragan and will instead apply its established law, as Rule 3 governs the timing requirements of the Federal Rules but does not affect state statutes of limitations.
LSD+ Case Briefs
Features
- DeepDive for detailed case analysis
- Over 50,000 existing case briefs
- Instant briefs for another 6,000,000 cases
- Highlight dictionary for legal term definitions
- Social learning with chat and high points
Over 50,000 Cases Briefed
LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.
14-Day Free Trial
Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.
Integrated Legal Dictionary
Lawyers and judges love to use big words. And Latin, for some reason.
Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.
DeepDive
DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.
Brief anything. Instantly.
Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.
Social Learning with Chat and High Points
Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.
Real-Time Brief Feedback
Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.