Hanna v. Plumer
Encyclopedia
Hanna v. Plumer, 380 U.S. 460
(1965), was a decision by the Supreme Court of the United States
, in which the Court further refined the Erie doctrine
regarding when and by what means federal courts
are obliged to apply state law
in cases brought under diversity jurisdiction
. The question in the instant case was whether Federal Rules of Civil Procedure
governing service of process
should yield to state rules governing the service of process in diversity cases. The Court ruled that under the facts of this case, federal courts shall apply the federal rule.
4 (e)(2)(b) required only that service be made on a competent adult
at the residence
of the defendant. The plaintiff left process at the residence of the executor, and so complied with the federal rule but not the state rule. The District Court granted summary judgment to the executor for the plaintiff's failure to make adequate service of process, ruling that the state rule applied based on the Supreme Court's prior precedents. The United States Court of Appeals for the First Circuit
affirmed.
Earl Warren
delivered the majority opinion, which held that the adoption of rule 4(d)(1) did not overstep the constitutional boundaries or the legislative intent
of Congress
in enacting the Rules Enabling Act
(28 U.S.C. 2072) noting that "...the test must be whether a rule really regulates procedure..." Thus it was appropriate to apply Rule 4(d)(1) (now FRCP (4)(e)(2)) and not Massachusetts law in the Federal District Court. In reaching this decision the Court stated that the rule that state and federal courts should reach outcomes substantially the same was not a "talisman
" and that there were more basic principles governing Erie Railroad v. Tompkins and its progeny (that is, cases dealing with how Federal courts should apply state law). The purpose of Erie was to 1) discourage "forum shopping" and 2) avoid inequitable administration of laws. The instant case must be viewed in this light. While the outcome of the current case is determined by which law is applied, the rights
in question are not substantial enough to create problems of unequal protection and because in Erie and its progeny there was no explicit conflict between state and federal rules. Thus, in those cases the Court held not that state rules trumped federal rules but that the federal rules, narrowly construed, did not cover the dispute whereas in the current case the federal and state
laws are in direct conflict and the court has been instructed to follow the Federal Rule in these cases and there is no constitutional reason not to do so. In short, outcome determinative judgments are important under the American
legal system for deciding if a state or federal rule applies but in the current case denying the federal rule would remove any power whatsoever the federal courts have over their procedures. Harlan argued that forum shopping and equitable administration of laws were not the only concerns in Erie because public
uncertainty over which laws govern would be debilitating and therefore state law controls where it is an issue of affecting "primary decisions respecting human conduct." Under this understanding federal laws could be trumped by a state law, whether substantive or procedural law, meaning that Harlan's test is somewhere in between the "outcome determinative test" which gives extreme deference to state laws and the "forum shopping/equitable administration test" given in the case at hand, which states that a party must "substantially" raise equal protection issues.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1965), was a decision by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
, in which the Court further refined the Erie doctrine
Erie doctrine
In United States law, the Erie doctrine is a fundamental legal doctrine of civil procedure mandating that a federal court in diversity jurisdiction must apply state substantive law....
regarding when and by what means federal courts
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
are obliged to apply state law
State law
In the United States, state law is the law of each separate U.S. state, as passed by the state legislature and adjudicated by state courts. It exists in parallel, and sometimes in conflict with, United States federal law. These disputes are often resolved by the federal courts.-See also:*List of U.S...
in cases brought under diversity jurisdiction
Diversity jurisdiction
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction in civil procedure in which a United States district court has the power to hear a civil case where the persons that are parties are "diverse" in citizenship, which generally indicates that they are...
. The question in the instant case was whether Federal Rules of Civil Procedure
Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...
governing service of process
Service of process
Service of process is the procedure employed to give legal notice to a person of a court or administrative body's exercise of its jurisdiction over that person so as to enable that person to respond to the proceeding before the court, body or other tribunal...
should yield to state rules governing the service of process in diversity cases. The Court ruled that under the facts of this case, federal courts shall apply the federal rule.
Background of the case
On February 6, 1963, petitioner, a citizen of Ohio, filed her complaint in the District Court for the District of Massachusetts, claiming damages in excess of $10,000 for personal injuries resulting from an automobile accident in South Carolina, allegedly caused by the negligence of one Louise Plumer Osgood, a Massachusetts citizen deceased at the time of the filing of the complaint. Respondent, Mrs. Osgood's executor and also a Massachusetts citizen, was named as defendant. The Massachusetts rule at the time required personal service of process on the executor of an in-state defendant, while Fed. R. Civ. P.Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...
4 (e)(2)(b) required only that service be made on a competent adult
Adult
An adult is a human being or living organism that is of relatively mature age, typically associated with sexual maturity and the attainment of reproductive age....
at the residence
House
A house is a building or structure that has the ability to be occupied for dwelling by human beings or other creatures. The term house includes many kinds of different dwellings ranging from rudimentary huts of nomadic tribes to free standing individual structures...
of the defendant. The plaintiff left process at the residence of the executor, and so complied with the federal rule but not the state rule. The District Court granted summary judgment to the executor for the plaintiff's failure to make adequate service of process, ruling that the state rule applied based on the Supreme Court's prior precedents. The United States Court of Appeals for the First Circuit
United States Court of Appeals for the First Circuit
The United States Court of Appeals for the First Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* District of Maine* District of Massachusetts...
affirmed.
The court's decision
Chief JusticeChief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Earl Warren
Earl Warren
Earl Warren was the 14th Chief Justice of the United States.He is known for the sweeping decisions of the Warren Court, which ended school segregation and transformed many areas of American law, especially regarding the rights of the accused, ending public-school-sponsored prayer, and requiring...
delivered the majority opinion, which held that the adoption of rule 4(d)(1) did not overstep the constitutional boundaries or the legislative intent
Legislative intent
In law, the legislative intent of the legislature in enacting legislation may sometimes be considered by the judiciary when interpreting the law...
of Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
in enacting the Rules Enabling Act
Rules Enabling Act
The Rules Enabling Act is an Act of Congress that gave the judicial branch the power to promulgate the Federal Rules of Civil Procedure. Amendments to the Act allowed for the creation of the Federal Rules of Criminal Procedure and other procedural court rules...
(28 U.S.C. 2072) noting that "...the test must be whether a rule really regulates procedure..." Thus it was appropriate to apply Rule 4(d)(1) (now FRCP (4)(e)(2)) and not Massachusetts law in the Federal District Court. In reaching this decision the Court stated that the rule that state and federal courts should reach outcomes substantially the same was not a "talisman
Amulet
An amulet, similar to a talisman , is any object intended to bring good luck or protection to its owner.Potential amulets include gems, especially engraved gems, statues, coins, drawings, pendants, rings, plants and animals; even words said in certain occasions—for example: vade retro satana—, to...
" and that there were more basic principles governing Erie Railroad v. Tompkins and its progeny (that is, cases dealing with how Federal courts should apply state law). The purpose of Erie was to 1) discourage "forum shopping" and 2) avoid inequitable administration of laws. The instant case must be viewed in this light. While the outcome of the current case is determined by which law is applied, the rights
Rights
Rights are legal, social, or ethical principles of freedom or entitlement; that is, rights are the fundamental normative rules about what is allowed of people or owed to people, according to some legal system, social convention, or ethical theory...
in question are not substantial enough to create problems of unequal protection and because in Erie and its progeny there was no explicit conflict between state and federal rules. Thus, in those cases the Court held not that state rules trumped federal rules but that the federal rules, narrowly construed, did not cover the dispute whereas in the current case the federal and state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
laws are in direct conflict and the court has been instructed to follow the Federal Rule in these cases and there is no constitutional reason not to do so. In short, outcome determinative judgments are important under the American
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
legal system for deciding if a state or federal rule applies but in the current case denying the federal rule would remove any power whatsoever the federal courts have over their procedures. Harlan argued that forum shopping and equitable administration of laws were not the only concerns in Erie because public
Public
In public relations and communication science, publics are groups of individuals, and the public is the totality of such groupings. This is a different concept to the sociological concept of the Öffentlichkeit or public sphere. The concept of a public has also been defined in political science,...
uncertainty over which laws govern would be debilitating and therefore state law controls where it is an issue of affecting "primary decisions respecting human conduct." Under this understanding federal laws could be trumped by a state law, whether substantive or procedural law, meaning that Harlan's test is somewhere in between the "outcome determinative test" which gives extreme deference to state laws and the "forum shopping/equitable administration test" given in the case at hand, which states that a party must "substantially" raise equal protection issues.