Sampson v. Channell
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Sampson v. Channell, 110 F.2d 754 (1st Cir. 1940),[1] was a United States Court of Appeals decision interpreting the application of the Erie doctrine (derived from Erie v. Tompkins) where diversity jurisdiction is invoked in a choice of law situation, where a court in one state may be called upon to apply the laws of another state.[2]
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Sampson v. Channell | |
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Court | United States Court of Appeals for the First Circuit |
Decided | March 27, 1940 |
Citation(s) | 110 F.2d 754 (1st Cir. 1940) |
Case history | |
Prior history | 27 F. Supp. 213 (D. Mass. 1939) |
Court membership | |
Judge(s) sitting | Scott Wilson, Calvert Magruder, Peters |
Case opinions | |
Majority | Magruder, joined by Wilson |
Dissent | Peters |
The Appellate court concluded that the federal district court must act as if it were a state court of the state in question, so long as the application of the state's substantive law might change the outcome of the case. This led to the anomaly that the federal courts must treat certain things (such as burdens of proof and statutes of limitations) as substantive law, even if the state treats these same things as merely procedural, as a justification for using their own law instead of the law of another state.