Salve Regina College v. Russell
113 L. Ed. 2d 190, 499 U.S. 225, 1991 U.S. LEXIS 1714 (1991)
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Rule of Law:
A federal court of appeals must review a district court's determination of state law under a de novo standard of review. Appellate courts may not defer to a district court's perceived expertise in the law of the state in which it sits.
Facts:
- Sharon L. Russell was admitted to Salve Regina College's nursing program in 1983.
- Russell, who was 5'6" tall and weighed over 300 pounds, faced commentary and concern from college officials about her obesity.
- During her junior year, Russell signed a document described as a 'contract' that required her to lose an average of two pounds per week to remain in the nursing program.
- When Russell failed to meet the weight-loss commitments, the college asked her to withdraw from the program, which she did.
- Russell then transferred to another college's nursing program where she had to repeat her junior year, delaying her graduation by a year.
Procedural Posture:
- Sharon L. Russell filed a civil action against Salve Regina College in the U.S. District Court for the District of Rhode Island based on diversity of citizenship.
- At the close of all evidence, the District Court denied the college's motion for a directed verdict on the breach-of-contract claim.
- The district judge, predicting that the Rhode Island Supreme Court would apply the doctrine of substantial performance to this type of contract, submitted the claim to the jury.
- The jury returned a verdict in favor of Russell and awarded damages.
- Salve Regina College (appellant) appealed the judgment to the U.S. Court of Appeals for the First Circuit.
- The Court of Appeals affirmed, stating that it gave 'customary appellate deference' to the district court's interpretation of state law.
- Salve Regina College (petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Must a federal court of appeals review a district court's determination of state law de novo, rather than under a more deferential standard?
Opinions:
Majority - Justice Blackmun
Yes, a federal court of appeals must review a district court's determination of state law de novo. Deferential review is inconsistent with the principles of Erie R. Co. v. Tompkins, as it undermines the goals of doctrinal coherence and preventing forum shopping. Appellate courts are structurally better suited for resolving complex legal questions through multijudge panels and focused legal briefing, unlike district courts which are primarily focused on fact-finding and managing fast-paced trials. The proposition that a district judge can better 'intuit' an unsettled question of state law is foreclosed by Erie, as the bases of state law are presumed to be communicable and discoverable through reasoned analysis, not a 'brooding omnipresence in the sky'.
Dissenting - Chief Justice Rehnquist
No, a federal court of appeals is not required to review a district court's determination of state law de novo and may afford deference to the district court's conclusion. It is a sensible allocation of judicial resources for an appellate court to give special weight to a local district judge's assessment of unsettled state law, as that judge often has valuable experience and perception of judicial behavior in that state. This approach does not involve abdicating the appellate function but rather recognizes that in predicting how a state's highest court might rule, experience is as important as logic. Imposing a rigid de novo standard on appellate courts improperly compartmentalizes an inquiry that has traditionally been left to common sense and good judgment.
Analysis:
This decision establishes a uniform national standard for appellate review of district court state-law determinations in diversity cases, resolving a circuit split on the issue. By mandating de novo review, the Court reinforces the principles of Erie v. Tompkins, aiming to ensure that the outcome of a case does not depend on whether it is tried in federal or state court. The ruling promotes consistency in the application of state law by federal courts and prevents the development of a separate body of 'federal' state law shaped by the potentially idiosyncratic views of individual district judges.
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