Erie Railroad Co. v. Tompkins
Citation: 304 U.S. 64 (U.S. Supreme Court, 1938)
Facts
Harry Tompkins was injured while walking along a footpath next to Erie Railroad tracks in Pennsylvania when he was struck by an open refrigerator door on a passing train. Tompkins sued in federal court in New York based on diversity jurisdiction. Under Pennsylvania state law he would have been considered a trespasser owed only a duty to avoid willful injury, but under the prevailing federal general common law (from Swift v. Tyson) he might recover as a licensee.
Issue
Whether federal courts sitting in diversity may apply a federal general common law that differs from the law of the state in which they sit.
Holding
The Supreme Court overruled Swift v. Tyson and held that there is no federal general common law; in diversity cases, federal courts must apply the substantive law of the state in which they sit, including that state’s common law as declared by its highest court.
Rule
Except in matters governed by the federal Constitution or acts of Congress, the law to be applied in a diversity case is the law of the state in which the federal court sits. There is no federal general common law. A federal court may not declare an independent body of federal common law for cases governed by state law.
Significance
Erie is one of the most important cases in all of federal courts and procedure. It overturned nearly a century of Swift v. Tyson doctrine, established that federal courts must apply state substantive law in diversity cases, and set the stage for the entire Erie doctrine — including Guaranty Trust, Byrd, and Hanna.