Day & Zimmermann, Inc. v. Challoner
46 L. Ed. 2d 3, 423 U.S. 3, 1975 U.S. LEXIS 90 (1975)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
In a federal court exercising diversity jurisdiction, the court must apply the conflict-of-laws rules of the state in which it sits, and is not free to engraft federal exceptions or modifications onto those state rules.
Facts:
- Respondents suffered death and personal injury.
- These injuries resulted from the premature explosion of a 105-mm. howitzer round.
- The explosion occurred in Cambodia.
- Respondents sued petitioner seeking to recover damages for these events.
Procedural Posture:
- Respondents sued petitioner in the United States District Court for the Eastern District of Texas, alleging federal jurisdiction based on diversity of citizenship.
- The District Court held that the Texas law of strict liability in tort governed and submitted the case to the jury on that theory.
- The jury returned a judgment in favor of respondents.
- Petitioner appealed to the United States Court of Appeals for the Fifth Circuit as appellant, and respondents were appellees.
- The Court of Appeals affirmed the judgment of the District Court, but declined to apply Texas choice-of-law rules, based on its interpretation of federal choice-of-law principles derived from an earlier decision.
- Petitioner filed a petition for certiorari with the Supreme Court of the United States.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal court sitting in a diversity jurisdiction case have the authority to disregard the choice-of-law rules of the state in which it sits and apply a federal choice-of-law rule instead?
Opinions:
Majority - Per Curiam
No, a federal court sitting in a diversity jurisdiction case does not have the authority to disregard the choice-of-law rules of the state in which it sits and apply a federal choice-of-law rule instead. The Court reaffirmed its longstanding decision in Klaxon Co. v. Stentor Electric Mfg. Co., which established that federal courts in diversity cases must conform to the conflict-of-laws rules prevailing in the state courts where they sit. The Court explained that to do otherwise would disturb the equal administration of justice between state and federal courts sitting side by side, as emphasized in Erie R. Co. v. Tompkins. Federal courts are not permitted to create or adopt exceptions or modifications to state conflict-of-laws rules that have not been adopted by the forum state itself. Therefore, the Court of Appeals should have identified and followed the Texas conflicts rule.
Concurring - Mr. Justice Blackmun
While agreeing that federal courts must apply the forum state's choice-of-law rules, the Court of Appeals is not prevented from concluding that Texas state courts themselves would apply the Texas rule of strict liability. Justice Blackmun concurred to clarify that the per curiam opinion does not necessarily compel the Court of Appeals to conclude that only the law of Cambodia is applicable. He emphasized that on remand, the Court of Appeals is to determine and flatly apply Texas's conflict-of-laws rules, and if, under those rules, it finds that Texas state courts would apply Texas law of strict liability, then no violation of Klaxon would occur.
Analysis:
This case strongly reinforces the principles of federalism and the Erie doctrine by reasserting that federal courts, when exercising diversity jurisdiction, must act as an alter ego of the state courts in the forum state regarding choice-of-law rules. This prevents forum shopping between state and federal courts based on differing conflict-of-laws rules, ensuring that the outcome of a case is substantially the same regardless of whether it is brought in state or federal court in the same jurisdiction. It highlights the Supreme Court's commitment to maintaining consistency and equality in the administration of justice between coordinate state and federal judicial systems.
