Facts of the Case
After a car accident in South Carolina, Hanna brought a claim against Plumer, the executor of the estate of the driver who hit him. Since Hanna was a resident of Ohio, and Plumer was a resident of Massachusetts, the case was heard by a federal court in Massachusetts sitting in diversity jurisdiction. Plumer was served by leaving copies of the summons with his wife, in accordance with the Federal Rules of Civil Procedure. However, Plumer successfully sought summary judgment at trial because Massachusetts law requires service to be delivered by hand.
The parties argued on appeal over how the Erie doctrine applied to this case. Plumer asserted that it would find a question to be substantive rather than procedural under the outcome-determinative test when applying federal law would alter the outcome of the case. He pointed out that applying federal law would change the outcome of the case, which otherwise would be dismissed, so the state procedural requirements and the grant of summary judgment should be upheld.
Questions
How should the court determine whether to apply the state or federal rule?
Conclusions
-
In cases when it is rationally possible to classify a law as either substantive or procedural, the federal courts have the authority to control their own practice and pleading procedures.
In a unanimous decision authored by Justice Warren, the Court ruled for Hanna. To raise the Erie doctrine, the Court reasoned, the effect of a procedural rule on the outcome of a case must abridge, enlarge, or modify the substantive law. There was no change to a substantive right here because the plaintiff simply could refile the case or serve the defendant personally. This issue thus related only to procedural requirements, so applying the outcome-determinative test was not appropriate.
Pleading, Discovery, and the Federal Rules: Exploring the Foundations of Modern Procedure
Engage Volume 12, Issue 3, November 2011
Note from the Editor: In December 2010, the Federalist Society heard from a number of...
