Guaranty
Trust Co. v. York
326
U.S. 99 (1945)
Yeazell,
pp. 276-278
Facts: The plaintiffs sued for
some stuff. The defendant countered by
claiming that the New York statute of limitations
barred the plaintiffs’ suit. The plaintiffs
claimed that the New York statute of limitations did
not apply under Erie because their claim was in
equity rather than in law. The Second
Circuit found that the plaintiffs were right and that their suit could
proceed. The defendant appealed to the Supreme
Court.
Issue: Can the federal courts hear
the suit even though it would be barred if it took place in state court between
non-diverse parties?
Rule: NEW RULE, AGAIN! The outcome of the case in federal court
should be the same as it would be in state court.
Analysis: The Court looks to the
intent of the ruling in Erie and asserts that it doesn’t
matter whether state law is substantive or procedural as long as it will have
an impact on the outcome of a case.
Conclusion: The judgment was reversed
and the case was remanded, presumably to be dismissed by application of the New York statute of limitations.
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Constitutional Command of Erie
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