Hanna v. Plumer
380 U.S. 460, 85 S. Ct. 1136, 14 L. Ed. 2d 8 (1965)
who was from Ohio was involved in a car accident in South Carolina with
Osgood, who lived in Massachusetts.Hanna sued in Federal Court based on diversity jurisdiction.
was killed in the accident.so technically Hanna sued her estate, represented by Plumer (also from
served process by leaving documents with Plumer's wife, which complied Federal Rule 4(e)(2), but not Massachusetts law.
moved to dismiss because this method of serving process violated
has a Statute of Limitations on
serving process to executors of estates, so if this case was dismissed, Hanna wouldn't have time to try again.
cited the Erie Doctrine.
Federal Trial Court granted the motion to dismiss.Hanna appealed.
argued that the Federal Rules of Civil Procedure (FRCP) should take precedence in diversity
argued that the outcome-determinativetest of the Erie
Doctrine (and Guaranty Trust Co. v. York
(326 U.S. 9 (1945))) must be used, and under that
test Plumer wins.
Federal Appellate Court affirmed.Hanna appealed.
The Federal Appellate
Court found that that the State Statute should govern because it is
substantive rather than merely procedural.
US Supreme Court reversed and found that the FRCP governs.
US Supreme Court found that if there was no conflict with State law, the
FRCP would control, but the Erie Doctrine presents a problem.
Court refined the outcome-determinative test from Guaranty Trust by saying that it is not absolute.
Court felt that the Erie Doctrine
is meant to remedy problems arising from big differences between State and Federal law, not
tiny, insubstantial ones.
Court suggested that the difference between Massachusetts law and the
FRCP in this case was not that big.
the Court, the Erie Doctrine
has two goals:
unfair differences in administration of justice between State and
Court found that the competing rules, though outcome-determinative, have
little or no relevance to the choice of a forum.
wouldn't decide to file in State versus Federal Court based solely on
the choice between these two laws.
under the Supremacy Clause of the
Constitution, Federal laws always trump State laws.Therefore, since the Rules
Enabling Act (28 USC § 2072),
and the FRCP are Federal Statutes, anything explicitly codified there will
trump any State rules of civil procedure.