Hanna v. Plumer Case Brief

Facts of the case

After a car accident in South Carolina, Hanna brought a claim against Plumer, the executor of the estate of the driver who hit him. Since Hanna was a resident of Ohio, and Plumer was a resident of Massachusetts, the case was heard by a federal court in Massachusetts sitting in diversity jurisdiction. Plumer was served by leaving copies of the summons with his wife, in accordance with the Federal Rules of Civil Procedure. However, Plumer successfully sought summary judgment at trial because Massachusetts law requires service to be delivered by hand.The parties argued on appeal over how the Erie doctrine applied to this case. Plumer asserted that it would find a question to be substantive rather than procedural under the outcome-determinative test when applying federal law would alter the outcome of the case. He pointed out that applying federal law would change the outcome of the case, which otherwise would be dismissed, so the state procedural requirements and the grant of summary judgment should be upheld.

Why is the case important?

Plaintiff sued Defendant in federal court in Massachusetts based on diversity jurisdiction. Plaintiff served Defendant by mail pursuant to Rule 4(d)(1) of the Federal Rules of Civil Procedure. Defendant moved to quash the summons on the grounds that the Massachusetts service statute applied and it required personal service in order to be effective.

Question

Should the District Court have applied Federal Rules of Civil Procedure 4(d)(1) instead of the state statute governing the method of process?

ANSWER

Yes.
Under Guaranty Trust Co. v. York, 326 U.S. 99, 65 S.Ct. 1464, 89 L.Ed. 2079 (1945), whether the state or federal law is to be applied is not just whether the law is substantive or procedural, or whether it is outcome determinative, but whether it complies with the policies underlying the Erie doctrine.

CONCLUSION

The Court held that in a suit where a plaintiff happened to be a non-resident, and a right was enforceable in a federal as well as in a state court, the forms and mode of enforcing the right may at times, vary because the two judicial systems were not identical. The Court held that the adoption of Fed. R. Civ. P. 4(d)(1) , designed to control service of process in diversity actions, neither exceeded the congressional mandate embodied in the Rules Enabling Act nor transgressed constitutional bounds, and that Rule 4(d)(1) was therefore the standard against which the district court should have measured the adequacy of the service.

  • Advocates: –
  • Petitioner: Hanna
  • Respondent: Plumer
  • DECIDED BY:Warren Court
  • Location: –
Citation: 380 US 460 (1965)
Argued: Jan 21, 1965
Decided: Apr 26, 1965
Hanna v. Plumer Case Brief