Erie Railroad Company v. Tompkins (1900)
- Docket
- 367
- Decided
- 1900-1940-
Summary
Question: Should federal courts sitting in diversity jurisdiction apply state or federal law? Conclusion: Writing for the majority, Justice Louis Dembitz Brandeis decided that it was time to depart from the rule in Swift and seek greater uniformity in how the law is applied. Arguing that the Swift decision went beyond the boundaries of the appropriate constitutional role for the judicial branch, Brandeis wrote that federal courts are not entitled to create their own common law for issues that properly fall within state law. He also suggested that the impact of that decision created vertical separation of powers concerns involving the federal government and the states. Instead, he felt that applying state substantive law would lead to more predictable outcomes for litigants and greater efficiency for courts. Thus, the Court concluded that in diversity jurisdiction cases, courts should apply substantive state law and federal procedural law unless there is a conflict between substantive state and federal law. Justice Stanley Forman Reed concurred, arguing that the Swift ruling was erroneous rather than unconstitutional. Justices Pierce Butler and Clark McReynolds dissented. Butler pointed out that neither party had raised a constitutional question in the case, and therefore the Court had decided it on inappropriate grounds. He felt that the Court went beyond its appropriate role in Erie , not Swift .