Erie Railroad Co. v. Tompkins - Case Summary

Legal Case Summary

Facts

Harry Tompkins, a Pennsylvania citizen, was struck by an open door on a passing train of the Erie Railroad Co. while walking along the tracks. The incident caused him to lose an arm. This incident occurred in Pennsylvania and Tompkins filed a lawsuit in a federal court, as the Erie Railroad Co. incorporated in New York. Tompkins claimed that he was an invitee to whom Erie owed a duty of care, but Erie argued that under Pennsylvania law, Tompkins was a trespasser to whom it owed duty only to refrain from wilful or wanton harm.

Issues

The main issue of Erie v Tompkins case rested on a conflict between the federal common law and the state law. The federal courts, following Swift v Tyson, applied the general common law. However, Tompkins' right to sue the Railroad, considering whether he was a trespasser or an invitee, depended on Pennsylvania law. The Supreme Court had to determine which law the federal court sitting in diversity should apply: the Pennsylvania state law or the federal common law.

Analysis

The reversal of Swift v. Tyson effectively removed federal common law and initiated the use of the Erie doctrine, requiring federal courts to apply the substantive law of the states. This decision led to increased importance of state laws and reduced federal court authority in civil litigation (Schwartz, 2010). The Erie doctrine is considered a cornerstone of Civil Procedure in federal courts and has influenced many critical and controversial issues within the jurisdiction of the federal courts.

Decision

In a 5-4 decision, Justice Benjamin Cardozo writing for the majority held that there is no federal general common law, and hence, the federal court sitting in diversity should apply state law. The Court expressed that the provision in the Judiciary Act of 1789 allowing federal courts to create a common law in diversity cases (upon which Swift v. Tyson was based) was unconstitutional and contravened the Tenth Amendment. Instead, federal courts sitting in diversity are to apply substantive state law. The matter was remitted to the lower court to apply Pennsylvania's law where the Courts had previously held that he was a trespasser.

References

• Schwartz, B. (2010). Erie Railroad Co. v. Tompkins: A Study in Adjudication. The American Journal of Legal History, Vol. 9, No. 4.

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Journalist Brief

In simple terms, Erie v. Tompkins was a groundbreaking legal case. It questioned whether federal courts must follow state law or if they could create their own. Ultimately, the Supreme Court ruled federal courts must respect and enforce state laws where a case originates. The outcome gave states more influence over their laws, reducing the power of federal courts to make decisions based on their interpretation of the law. In essence, this ruling assured that people in similar situations will be treated the same under the law, irrespective of whether the case goes to state or federal court.

FAQs

What is the Erie Doctrine?

It is a legal principle from this case, which requires federal courts to apply substantive state law in cases not involving federal question jurisdiction.

Why is Erie v. Tompkins significant?

It is significant because it changed the role of federal courts in cases involving state law by ending their ability to interpret common law for themselves and reinforcing the application of state laws.

What is the impact of Erie v. Tompkins today?

It established the broad principle that federal courts sitting in diversity apply state law, this precedent is still applied and referred to in today's federal court cases.