Hanna v. Plumer
Citation: 380 U.S. 460 (U.S. Supreme Court, 1965)
Facts
Hanna brought a diversity suit in Massachusetts federal court arising from a car accident. She served process by leaving copies with the defendant’s wife at his residence, as permitted by FRCP Rule 4. Massachusetts state law required personal in-hand service on the executor of an estate. Plumer moved to dismiss for insufficient service.
Issue
Whether a Federal Rule of Civil Procedure that conflicts with a state procedural rule must yield to state law under the Erie doctrine.
Holding
The Supreme Court held that service under FRCP Rule 4 was valid and that the Federal Rule controlled. When a valid Federal Rule of Civil Procedure directly collides with state law, the Federal Rule governs as long as it does not exceed congressional authority under the Rules Enabling Act.
Rule
The Erie analysis is modified when a Federal Rule directly on point exists: (1) if a valid FRCP governs, it applies unless it exceeds the scope of the Rules Enabling Act or is unconstitutional; (2) the outcome-determinative test from York applies only in the “relatively unguided Erie choice” situation — i.e., when no Federal Rule directly addresses the matter. The “twin aims” of Erie are to discourage forum shopping and avoid inequitable administration of the law.
Significance
Hanna is essential for understanding the full Erie framework. It establishes a two-track analysis: one track for cases where a Federal Rule directly applies (Rules Enabling Act analysis), and another for the unguided Erie choice (outcome-determinative/twin aims analysis). It is taught alongside Erie, York, and Byrd as a capstone to the Erie doctrine.