Erie Railroad Co v Tompkins 1938

Erie Railroad Co v Tompkins 1938

Erie Railroad Co v Tompkins [1938] 304 US 64 is a US landmark case decided by the Supreme Court in 1938. The case addressed the issue of whether federal common law could apply in certain situations when there is a lack of controlling state law.

The case originated from an accident involving Harry Tompkins, who was walking along the Erie Railroad tracks in Pennsylvania when he was struck by a protruding door on one of the railroad's passing trains. Tompkins sued the Erie Railroad Company in federal court, alleging negligence.

The central question in the case was whether federal common law or state law should be applied to determine the railroad's liability. At the time, federal courts often applied federal common law in diversity cases, which involved disputes between citizens of different states. In this case, there was no specific state law governing the circumstances, so the lower federal courts relied on federal common law to find the railroad liable.

However, the Supreme Court, in a 6-2 decision, rejected the application of federal common law in diversity cases and held that federal courts should not create general common law rules that bind state courts in such cases. Instead, state law should govern unless there is a specific federal law applicable to the issue.

The Court's decision in Erie Railroad Co v Tompkins effectively overturned the long-standing doctrine of federal common law in diversity cases established in Swift v Tyson [1842]. It emphasised the importance of state law and the need for federal courts to adhere to state court decisions and statutes when deciding cases based on diversity jurisdiction.

This case established the Erie doctrine, which requires federal courts to apply state substantive law and federal procedural law in diversity cases. It significantly affected the development of American legal practice by reinforcing the principle that federal courts should not create substantive common law.

The Erie Railroad Co v Tompkins decision had a broad impact on federal jurisdiction and the relationship between federal and state law. It affirmed the principle that federal courts should respect state sovereignty and respect the diversity of state laws when adjudicating cases.
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