Sampson v. Channell
Citation and Court
110 F.2d 754 (1st Cir. 1940)
Facts
A Massachusetts federal court sitting in diversity heard a tort claim arising from an automobile accident in Maine. The question arose whether the federal court should apply Massachusetts or Maine’s choice-of-law rules to determine which state’s substantive law governed.
Issue
After Erie Railroad Co. v. Tompkins (1938), must a federal court sitting in diversity apply the choice-of-law rules of the state in which it sits, rather than an independent federal conflicts methodology?
Holding
A federal diversity court must apply the choice-of-law rules of the state in which it sits; Erie requires federal courts to follow state law, and choice-of-law rules are part of the state’s substantive law for Erie purposes.
Rule / Doctrine
Erie’s requirement that federal courts in diversity cases apply state substantive law extends to the forum state’s choice-of-law rules. A federal court cannot develop an independent federal conflicts-of-laws methodology; it must apply the choice-of-law rules of the state in which it sits. This was later confirmed by the Supreme Court in Klaxon Co. v. Stentor Electric Manufacturing Co. (1941).
Significance
Sampson v. Channell anticipates the Supreme Court’s ruling in Klaxon v. Stentor (1941), which definitively held that federal diversity courts must apply the forum state’s choice-of-law rules. It is an important step in the development of Erie doctrine as applied to conflicts of law.