Contracts

Erie R.R. Co. v. Tompkins — Study Notes

304 U.S. 64 (1938)

Study notes for Erie R.R. Co. v. Tompkins: professor notes, cold call prep, exam angles, and memory aids.

Federal courts must apply state substantive law in diversity jurisdiction cases.
Professor Notes

Erie R.R. Co. v. Tompkins is a landmark case that defines the relationship between federal and state law when federal courts exercise diversity jurisdiction. The Supreme Court's decision emphasized the need for uniformity in the application of state law, thus rejecting the notion of federal common law in diversity cases. Professors will highlight how this case reversed the earlier precedent from Swift v. Tyson, which allowed federal courts to create their own common law in such situations. This ruling underscores the importance of state sovereignty and the principle that parties should be able to predict legal outcomes based on the laws of the state in which they live or where the incident occurred.

Cold Call Prep
  1. 1What was the importance of the Erie R.R. Co. v. Tompkins decision in relation to federalism?
  2. 2How did the Court differentiate between substantive and procedural law in this case?
  3. 3What was the previous standard established by Swift v. Tyson, and how did Erie R.R. Co. v. Tompkins change this standard?
  4. 4Can you explain the implications of this case for future diversity jurisdiction cases?
  5. 5What factors did the Court consider when deciding that state law should apply?
  6. 6In what ways does this case affect the litigation strategies for parties in federal versus state courts?
  7. 7What is the broader impact of this case on the interpretation of the Rules of Decision Act?
Mnemonic Device

E.R.I.E. - Establishes Rules for Incorporating Each state's law.

Distinguish From
CaseDistinction
Swift v. TysonSwift permitted federal courts to use federal common law, which was rejected in Erie.
Clark v. Paul Gray, Inc.Clark reaffirmed that state law is applicable in diversity cases post-Erie.
Byrd v. Blue Ridge Rural Elec. Coop., Inc.Byrd clarified the federal court's application of procedural law while upholding Erie’s rule on substantive law.
Policy Arguments

For the Rule

Applying state law promotes fairness and predictability in legal outcomes for litigants, respecting state sovereignty.

Against the Rule

Limiting federal courts to state law may lead to inconsistent applications and varying standards across jurisdictions.

Class Discussion Points
  • Discuss the impact of Erie R.R. Co. v. Tompkins on federalism and state rights.
  • Examine the tension between uniformity and diversity in the judicial system as illustrated by this case.
  • Analyze how legal practitioners adapt their strategies in light of the Erie doctrine.
  • Consider the implications of this ruling on legal research and writing in federal cases.
  • Debate whether the Erie decision has increased or decreased the efficiency of the federal court system.
Exam Angle

On exams, this case often appears in discussions about the boundaries of federalism, the application of state law in federal courts, and questions involving diversity jurisdiction. Students may be asked to discuss how this case influences legal strategies and the drafting of complaints.

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