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Erie Railroad Co. v. Tompkins

United States Supreme Court
304 U.S. 64, 58 S. Ct. 817, 82 L. Ed. 1188 (1938)

Written by Angela Patrick, JD

Facts

Harry Tompkins (plaintiff) was walking next to railroad tracks in Pennsylvania when he was hit by a passing train, fell on the tracks, and severed his arm. The train was owned by Erie Railroad Co. (Erie) (defendant), a New York company. The Pennsylvania common law regarding negligence claims favored Erie. In contrast, the negligence law in most other states favored Tompkins. Against this backdrop, Tompkins sued Erie in a New York federal court, invoking the federal court’s diversity jurisdiction. Relying on Swift v. Tyson, the federal court ruled that general law—essentially a form of federal common law—governed the negligence claim. Erie argued that this case fell under an exception to Swift that allowed Pennsylvania’s common law to still govern the negligence claim, but the district court disagreed. The district court then determined that the general law of negligence reflected the majority rule that favored Tompkins. Under this general-law standard, Tompkins won and recovered substantial damages.

Rule of Law

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Issue

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Holding and Reasoning (Brandeis, J.)

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Concurrence (Reed, J.)

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