Erie Railroad Co. V. Tompkins

bgcolor="6699FF" | Erie Railroad Co. v. Tompkins
align="center" | 100px
Supreme Court of the United States
bgcolor="6699FF" | Argued Jan. 31, 1938
Decided April 25, 1938
{| align="center"
valign="top"|Full case name: valign="top"|''Erie Railroad Company v. Harry J. Tompkins
valign="top"|Citations: valign="top"|304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188, 114 A.L.R. 1487
valign="top"|Prior history: valign="top"|
valign="top"|Subsequent history: valign="top"| }
bgcolor="6699FF" | Holding
In federal courts, except in matters governed by Federal Constitution or by acts of Congress, law to be applied in any case is law of the state. Court of Appeals for the Second Circuit reversed.
bgcolor="6699FF" | Court membership
{| align="center"
Chief Justice Charles Evans Hughes
Associate Justices Louis D. Brandeis, Pierce Butler, James C. McReynolds, Hugo L. Black, Stanley F. Reed, Owen J. Roberts, Harlan F. Stone, Benjamin N. Cardozo }
bgcolor="6699FF" | Case opinions
{| align="center"
Majority by: Brandeis
Joined by: Hughes, Black, Stone, Roberts
b>Dissent by: Butler, McReynolds
b>Concurrance in the judgment by: Reed
b>Not participating: Cardozo }
bgcolor="6699FF" | Laws applied
No specific law was applied to this case; rather, the Court determined that nothing in the Constitution gave Congress the power to permit the Courts to create a federal common law superseding the laws of the states.
Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938) established the modern law of diversity jurisdiction for United States federal courts.

Facts

Tompkins was injured in Pennsylvania as he walked along a well-worn footpath adjacent to railroad right-of-way. When a train passed by, Tompkins was struck by an object protruding from one of the cars. The train was owned by the Erie Railroad company, a New York corporation. Tompkins sued in a federal district court in New York. The district court, following the federal law at that time, applied neither New York nor Pennsylvania common law, but instead applied federal common law, which used an ordinary negligence standard for the duty of care owed to persons walking along railroad tracks, instead of Pennsylvania s common law wanton negligence standard for the duty of care to trespassers.

Issue

Should the federal court have applied the common law as derived by Pennsylvanias courts?

Rule

The court determined that nothing in the Constitution of the United States permits the U.S. Congress to empower federal courts to create their own common law. Therefore, the federal court was required to apply the law of whichever state it was sitting in, as though it were a state court of that state.

 

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