Erie Railroad Co. v. Tompkins

Facts

Tompkins, a citizen of Pennsylvania, was hurt on a dark night at Hughestown, Pennsylvania. He was walking along the Erie Railroad Company's right of way when a passing freight train injured him. He said he was hit by something that looked like a door sticking out from one of the moving cars. He claimed the railroad was negligent in operating or maintaining the train. He also claimed he was rightfully on the land as a licensee (a person there with permission), because he was on a commonly used, beaten footpath that ran for a short distance alongside the tracks. The railroad, a New York corporation, said its duty to Tompkins was no greater than the duty owed to a trespasser (a person on the land without permission). It relied on Pennsylvania law as declared by that State's highest court. Under that law, the railroad said, people who walk along a path beside the tracks, as opposed to crossing them, are trespassers, and a railroad is not liable for negligently injuring an undiscovered trespasser unless its conduct is wanton or wilful. Tompkins denied that the Pennsylvania courts had established any such rule. Because no Pennsylvania statute covered the subject, he argued that the federal courts should decide the railroad's duty as a matter of general law.

Issues

1. In a federal suit between citizens of different States, may the federal court disregard a State's common law, as declared by its highest court, and use its own independent judgment on questions of general law, as Swift v. Tyson allowed?
2. Did the Circuit Court of Appeals err when it declined to decide whether Pennsylvania law limited the railroad's duty to Tompkins, on the ground that his claim raised a question of general law?

Holding

The Court disapproved the doctrine of Swift v. Tyson. The railroad's liability to Tompkins was a question of state law, unwritten as well as written, so the Circuit Court of Appeals erred when it treated the question as one of general law and declined to decide the issue of state law. The Court did not itself decide what Pennsylvania law required; it sent the case back to the Circuit Court of Appeals for further proceedings.