Sampson v. Channell
Encyclopedia
Sampson v. Channell, 110 F.2d 754
(1st Cir. 1940), was a United States Court of Appeals
decision interpreting the application of the Erie doctrine (derived from Erie v. Tompkins) where diversity jurisdiction
is invoked in a choice of law
situation, where a court in one state may be called upon to apply the laws of another state.
The Appellate court concluded that the federal district court must act as if it were a state court of the state in question, so long as the application of the state's substantive law might change the outcome of the case. This led to the anomaly that the federal courts must treat certain things (such as burdens of proof and statutes of limitations) as substantive law, even if the state treats these same things as merely procedural, as a justification for using their own law instead of the law of another state.
husband and wife were hit by a car in Maine
; the driver of the other car was killed. The plaintiffs sued the estate (law)
of the dead driver in the Federal District Court in Massachusetts
, naming the executor
of the dead driver's estate as the defendant
and invoking the court's diversity jurisdiction
. The District court applied general principles of conflicts of law, determining that Maine law should control the case because that is where the accident happened. Under Maine law, the plaintiffs had the burden of proof to show that they were not contributorily negligent; had the court applied Massachusetts law, the defendant would have had the burden of showing plaintiff's contributorily negligence. The plaintiff appealed, contending that the Massachusetts Federal District Court should have applied the law of Massachusetts.
wrote that the policy of the Erie doctrine is not to allow the choice of forum be outcome determinative, stating that "it is unfair and unseemly to have the outcome of litigation substantially affected by the fortuitous existence of diversity of citizenship." Therefore, if applying the law of the state would change the outcome as it might in a burden-of-proof situation where one of the parties is dead, then the Federal Court will treat it as substantive, and apply the law of the state. The question remained as to which state's law would apply.
To determine the solution to this controversy, the Appellate Court asks and answers three questions:
Therefore, the judgment was reversed and remanded, with an instruction to the district court to apply the Massachusetts burden of proof.
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...
(1st Cir. 1940), was a United States Court of Appeals
United States court of appeals
The United States courts of appeals are the intermediate appellate courts of the United States federal court system...
decision interpreting the application of the Erie doctrine (derived from Erie v. Tompkins) where 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...
is invoked in a choice of law
Choice of law
Choice of law is a procedural stage in the litigation of a case involving the conflict of laws when it is necessary to reconcile the differences between the laws of different legal jurisdictions, such as sovereign states, federated states , or provinces...
situation, where a court in one state may be called upon to apply the laws of another state.
The Appellate court concluded that the federal district court must act as if it were a state court of the state in question, so long as the application of the state's substantive law might change the outcome of the case. This led to the anomaly that the federal courts must treat certain things (such as burdens of proof and statutes of limitations) as substantive law, even if the state treats these same things as merely procedural, as a justification for using their own law instead of the law of another state.
Facts
The plaintiffPlaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
husband and wife were hit by a car in Maine
Maine
Maine is a state in the New England region of the northeastern United States, bordered by the Atlantic Ocean to the east and south, New Hampshire to the west, and the Canadian provinces of Quebec to the northwest and New Brunswick to the northeast. Maine is both the northernmost and easternmost...
; the driver of the other car was killed. The plaintiffs sued the estate (law)
Estate (law)
An estate is the net worth of a person at any point in time. It is the sum of a person's assets - legal rights, interests and entitlements to property of any kind - less all liabilities at that time. The issue is of special legal significance on a question of bankruptcy and death of the person...
of the dead driver in the Federal District Court in Massachusetts
Massachusetts
The Commonwealth of Massachusetts is a state in the New England region of the northeastern United States of America. It is bordered by Rhode Island and Connecticut to the south, New York to the west, and Vermont and New Hampshire to the north; at its east lies the Atlantic Ocean. As of the 2010...
, naming the executor
Executor
An executor, in the broadest sense, is one who carries something out .-Overview:...
of the dead driver's estate as the defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
and invoking the court's 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 District court applied general principles of conflicts of law, determining that Maine law should control the case because that is where the accident happened. Under Maine law, the plaintiffs had the burden of proof to show that they were not contributorily negligent; had the court applied Massachusetts law, the defendant would have had the burden of showing plaintiff's contributorily negligence. The plaintiff appealed, contending that the Massachusetts Federal District Court should have applied the law of Massachusetts.
Issue
- Should the Fed. Dist. Court have used federal rules of procedure, or the rule of the state?
- If the rule of the state applies, which state is it?
Result
The United States Court of Appeals for the First CircuitUnited 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...
wrote that the policy of the Erie doctrine is not to allow the choice of forum be outcome determinative, stating that "it is unfair and unseemly to have the outcome of litigation substantially affected by the fortuitous existence of diversity of citizenship." Therefore, if applying the law of the state would change the outcome as it might in a burden-of-proof situation where one of the parties is dead, then the Federal Court will treat it as substantive, and apply the law of the state. The question remained as to which state's law would apply.
To determine the solution to this controversy, the Appellate Court asks and answers three questions:
- If the case had been brought in Massachusetts state court, would Massachusetts have brought in the Maine burden of proof?
Answer: no, because Massachusetts courts have already held the burden of proof to be merely procedural, and those are decided by the law of the forum. - Would the U.S. Supreme Court have any reason to reverse Massachusetts on such a decision?
Answer: no, because nothing in the Constitution requires Massachusetts to follow the same conflicts of law principles as any other state (especially since the Massachusetts law was statutory). - Does the invocation of diversity of citizenship change any of this?
Answer: no, because Federal District Courts are tied to the law of the state they are in, not free to choose the law of the state they prefer. Besides, then the Fed. Court would have treat the burden-of-proof law of Massachusetts as procedural in order to ignore it, but at the same time would have to treat the burden-of-proof law of Maine as substantive in order to apply it, which would be inconsistent.
Therefore, the judgment was reversed and remanded, with an instruction to the district court to apply the Massachusetts burden of proof.