Hanna v. Plumer
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| Hanna v. Plumer | |||||||||||
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| Argued January 21, 1965 Decided April 26, 1965 |
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| Holding | |||||||||||
| The adequacy of service of process in federal diversity jurisdiction cases should be measured by the Federal Rules of Civil Procedure, not state rules. First Circuit Court of Appeals reversed. | |||||||||||
| Court membership | |||||||||||
| Chief Justice: Earl Warren Associate Justices: Hugo Black, William O. Douglas, Tom C. Clark, John Marshall Harlan II, William J. Brennan, Potter Stewart, Byron White, Arthur Joseph Goldberg |
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| Case opinions | |||||||||||
| Majority by: Warren Joined by: Douglas, Clark, Brennan, Stewart, White, Goldberg Concurrence by: Black (without separate opinion) Concurrence by: Harlan |
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| Laws applied | |||||||||||
| Fed. R. Civ. P. 4; Mass. Gen. Laws, c. 197, ยง 9 (1958). | |||||||||||
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 doctrine set forth in Erie Railroad Co. v. Tompkins regarding when and how federal courts were to apply state law in cases brought under diversity jurisdiction. The question in Hanna was whether federal service of process rules should yield to state rules in diversity cases. The Court ruled that in this instance, federal courts should apply the federal rule.
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[edit] Background of the case
The case dealt with a personal injury claim brought by an Ohio plaintiff in the United States District Court for the District of Massachusetts against a Massachusetts defendant. The defendant was deceased by the time the suit was brought; the executor of his estate was accordingly named in the suit. The Massachusetts rule at the time required personal service of process on the executor of an in-state defendant, while Fed. R. Civ. P. 4(d)(1) 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.
[edit] The Court's decision
Chief Justice 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) and not Massachusetts law in the Federal District Court.
In reaching this decision the Court stated that the "rule" in Guaranty Trust Co. v. York 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 current 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. Furthermore, 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. In the current case the federal and state laws are in direct conflict. 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 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.
[edit] Harlan's concurrence
Harlan argued that forum shopping and equitable administration of laws were not the only concerns in Erie. He argues that uncertainity over which laws govern would be debilitating. Thus, 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. So, 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 must "substantially" raise equal protection issues.
