Hanna v. Plumer
380 U.S. 460, 85 S. Ct. 1136, 14 L. Ed. 2d 8 (1965)

  • Hanna, 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.
    • Osgood was killed in the accident.  so technically Hanna sued her estate, represented by Plumer (also from Massachusetts).
  • Hanna served process by leaving documents with Plumer’s wife, which complied Federal Rule 4(e)(2), but not Massachusetts law.
    • Plumer moved to dismiss because this method of serving process violated Massachusetts law.
      • Massachusetts 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.
      • Plumer cited the Erie Doctrine.
  • The Federal Trial Court granted the motion to dismiss.  Hanna appealed.
    • Hanna argued that the Federal Rules of Civil Procedure (FRCP) should take precedence in diversity actions.
    • Plumer argued that the outcome-determinative test of the Erie Doctrine (and Guaranty Trust Co. v. York (326 U.S. 9 (1945))) must be used, and under that test Plumer wins.
  • The 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.
  • The US Supreme Court reversed and found that the FRCP governs.
    • The US Supreme Court found that if there was no conflict with State law, the FRCP would control, but the Erie Doctrine presents a problem.
    • The Court refined the outcome-determinative test from Guaranty Trust by saying that it is not absolute.
    • The Court felt that the Erie Doctrine is meant to remedy problems arising from big differences between State and Federal law, not tiny, insubstantial ones.
      • The Court suggested that the difference between Massachusetts law and the FRCP in this case was not that big.
    • According the Court, the Erie Doctrine has two goals:
      • Prevent forum shopping.
      • Avoid unfair differences in administration of justice between State and Federal Courts.
    • The Court found that the competing rules, though outcome-determinative, have little or no relevance to the choice of a forum.
      • You wouldn’t decide to file in State versus Federal Court based solely on the choice between these two laws.
  • Remember, 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.