This legal question can be resolved by applying the Erie doctrine. The Erie Doctrine assists federal courts and lawyers in assessing the appropriate law that should be applied in diversity jurisdictional situations. Before beginning an analysis of the Erie Doctrine, it is useful to examine the legal history that led to the beginning of the doctrine. The Erie Doctrine is a fundamental legal doctrine in civil procedure law. It stipulates that a federal court must apply substantive law in cases of diversity jurisdiction. Swift`s decision was struck down by the Supreme Court`s decision in Erie R.R.c. Tompkins, 304 U.S. 64 (1938). Swift v. Tyson allowed federal judges sitting in one state to ignore general local decisions of state courts in the same state in cases based on diversity jurisdiction. The quick decision resulted in conflicting court decisions in the same state on the same point of law, depending on whether an plaintiff filed a case in a state or federal court. Erie Doctrine: The Erie Doctrine is based on a U.S. Supreme Court case, Erie Railroad Co.
v. Tompkins, 304 U.S. 64 (1938). The doctrine states that when federal courts are faced with the question of whether to apply federal law or state law in a legal dispute, they must apply state law in matters of substantive law. If the legal issue is based on a procedural issue, federal courts should apply federal law. The example described above is a typical example of a choice of law scenario. Two parties argue that a state court should apply the law of their jurisdiction. There is no federal jurisdiction over diversity because the disputed amount is less than $75,000. Nevertheless, there is a problem of choice of law. George, the plaintiff, would clearly want to recover the greatest financial relief available under California law.
On the other hand, Matt, the defendant, would like to limit his liability and implement Arizona law. The outcome of the dispute will largely determine which law the court applies. On what law should the regional court base its decision? The Erie Doctrine is a subject that every first-year law student must experience and engage with. While the nuances of the rule make it one of the most confusing issues in civil litigation, its basic principles are relatively simple. With the choice of law rules in the next subchapter, the Erie doctrine is based on the interaction of different legal laws. Before we get into the essence of the Erie doctrine, it is important to understand the context behind the development of the doctrine. Even in a scenario where a conflict issue is raised in federal court, the court`s jurisdiction does not have to be based on diversity. Indeed, the plaintiff and the defendant may come from the same State. (The conflict problem may arise because the legal controversy may have occurred in another state.) All of these scenarios will be discussed in more detail later in the sub-chapter. However, before examining these distinctions in more detail, it is important to understand the context in which these choice of law rules are triggered and the reasons why the courts regulate them.
First, it is important to note that a choice of law scenario may occur in state courts, while the application of the Erie doctrine is limited to litigation in federal courts. Some jurisdictions analyze various areas of law such as tort, real estate, and contracts with specific choice of law rules. In the area of tort law, the traditional rule is that the case is subject to the specific laws of the particular jurisdiction in which the damage occurred to the plaintiff. See Kaufman v. American Youth Hostels, Inc., 6 A.D.2d 223 (N.Y. A.D. 2d Dept. 1958).
For example, let`s take a previous example, a major problem with choice of law rules: each jurisdiction maintains its own rules in this area. Therefore, it is important to look at the local jurisdiction and rules of your particular jurisdiction. Another problem arising from the lack of uniformity in the application of choice of law rules between different legal systems is that it is impossible to cover all possible permutations and variations of regulations. However, in order to highlight the principles associated with the application of these choice of law rules, the remainder of this section highlights some of the basic choice of law rules applicable in many states. Decision Rules Act (GDR): The «GDR» is a law created by Congress in 1789 that states that in the absence of a federal law, constitutional provision or treaty, the courts must apply state law when it is applicable. This is one of the foundations of the Erie Doctrine. Story`s phrase «unless prohibited by state law» was a catalyst for a series of personal freedom laws enacted by Pennsylvania and other northern states. The laws prohibited state officials from disturbing fugitive or fugitive slaves in any capacity. Outliers could not be captured or imprisoned by government measures, cases could not be tried by state courts, and state officials could not offer help to those who wanted to recover slaves. The Fugitive Slave Act still existed, but only federal agents could enforce it.
This is called the «anti-command doctrine.» The GDR controversy that led to Erie was what happens when there is no federal or state law. Should the court apply customary federal law in such a case, or should it apply the customary law of the state (since there is no statutory law) to determine the outcome of this case? For example, like the Erie doctrine, rules of law (sometimes referred to as «conflict-of-laws rules») focus on the choice of laws of one jurisdiction over those of another jurisdiction in a particular dispute. As with the Erie doctrine, the court must determine which laws of jurisdiction to apply in a particular case. It is important to note that the Erie Doctrine applies only to cases brought before a federal court as to whether to apply federal or state law. For lawsuits brought in a state court but involving a choice between the laws of two different states, it is important to apply the choice of law rules described in the next subchapter. Modern Erie doctrine generally invokes the following criteria, depending on the circumstances of the case. One answer that seems most sensible would be for the State court to apply the law of its own jurisdiction; That is, the California court would apply its own law, with which it is most familiar. However, this is not always the rule. One of the reasons why this is not always the right choice is that it would lead the parties to make the «forum shop». Forum shopping refers to a situation where a party initiates a legal dispute in a particular jurisdiction where the party receives the greatest reward. Forum shopping is discouraged in the legal system and has a negative connotation.
Thus, if the state court still applied the law of its jurisdiction, plaintiffs would flock to a particular jurisdiction if it was known to allow the greatest financial rewards for a particular legal controversy or because it has the least restrictions. The courts strongly reject forum shopping for this reason. The court system tries to avoid «clogging» some courts with lawsuits, while leaving others «void» because their laws are less advantageous to plaintiffs. Keep in mind that this general overview of choice of law principles is not applicable in all jurisdictions. It is therefore important to research and review the rules of your jurisdiction before taking legal action in cases where these problems may arise. The court in the example above should apply Oklahoma law, which is the law of the state in which the federal court is located. There is a direct conflict between the compensation provided by Oklahoma law (which would allow Carl to recover from his injuries) and Venezuelan law (which would prevent Carl from recovering). See Klaxon Co. v. Stentor Electric Mfg. Co., 313 U.S. 487 (1941).
This issue will also be discussed in more detail in the next sub-chapter on choice of law. Similarly, a federal court must comply with the law of the state in which it is located when it allocates the burden of proof in a legal dispute. The burden of proof is the burden that the law places on a party to a controversy to prove the elements of a lawsuit. For example, a plaintiff has the burden of proof for elements of bodily injury, including the fact that the defendant was the direct cause of the accident and that the injuries sustained were due to the defendant`s actions. In such a case, the court will consider various factors in determining the applicable law. These factors include the extent to which the individual States concerned have an interest in having their law applicable to the case in question. Thus, in a case, as in the example above, where accidents occur between citizens of one state in a second state, the law of the state of citizenship of the parties will often prevail. .