Guaranty Trust Co. v. York
326 U.S. 99 (1945)
- Guaranty sued York in a Federal Court in New York. York moved to have the case dismissed.
- York argued that Guaranty’s claim was too late according to the New York Statute of Limitations.
- Guaranty argued that the Statute of Limitations is a procedural law, not a substantive law, and therefore was not within the doctrine established in Erie Railroad Co. v. Tompkins (304 U.S. 64 (1938)). Therefore, New York’s Statute of Limitations did not apply.
- aka the Erie Doctrine.
- The US Supreme Court found for York and dismissed the case.
- The US Supreme Court took the occasion replace with the substantive/procedural distinction that they came up with in Erie.
- The Court created a new standard that said that regardless of whether the case was argued in State or Federal court, the outcome should be substantially the same.
- That’s known as the outcome determinative test for deciding whether a piece of State law must be obeyed in Federal Courts.
- In this case, the Court found that the New York Statute of Limitations should be obeyed.