Erie Railroad v. Tompkins

Facts

Defendant, Erie Railroad Company (“Erie”), was a New York company. Plaintiff, Tompkins, was a Pennsylvania citizen who was injured in Pennsylvania by a passing Erie freight train while walking along a commonly used footpath that ran alongside the train tracks. Tompkins brought suit in New York federal court, claiming that the accident occurred due to negligence of operation or maintenance of the freight train. Tompkins asserted that he was rightfully on the premises as a licensee because he was on a commonly used footpath and was struck by something that looked like a door projecting from one of the moving train cars. Erie denied liability, arguing that its duty to Tompkins was no greater than that owed to a trespasser.

Erie argued that its duty to Tompkins should be determined by an alleged law of the state of Pennsylvania. Tompkins, in response, denied that this rule had been established in Pennsylvania courts, and argued that since there was no state statute on point, the railroad’s duty should be determined in federal courts as a matter of general law. The trial judge refused to rule that the applicable law precluded recovery, and the jury brought in a verdict of $30,000. This judgment was affirmed by the Circuit Court of Appeals, which held that it was unnecessary to consider what the law of Pennsylvania was because the question was one of general law, not local law. Erie argued that application of the Pennsylvania rule was required by §34 of the Federal Judiciary Act. The U.S. Supreme Court granted Erie’s petition for certiorari.