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Guaranty Trust Co v. York

This discussion explores the implications of the Erie Doctrine in diversity cases, focusing on the Guaranty Trust Co. v. York decision. It examines whether the state's statute of limitations (S/L) applies and evaluates the application of the Rules Decision Act (RDA). The analysis covers the bifurcated trial's burden of proof, the court's approach in determining outcome determinative factors, and the relevance of federal and state legal rules on case outcomes. Additionally, it compares related cases like Cohen v. Beneficial Industrial and Ragan v. Merchants Transfer, highlighting the complexities of federal and state jurisdictional issues.

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Guaranty Trust Co v. York

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  1. Guaranty Trust Co v. York • Issue? • State S/L in diversity cases • Decision • State S/L applies • Does the RDA apply to this case? • Why or why not? • What does that tell us about the basis for the Erie doctrine?

  2. Discussion Hypo Under Guaranty

  3. Burden of Proof Bifurcated Trial

  4. Guaranty Trust Co v. York • What test or approach does the court apply? • Outcome Determinative: • Diversity jurisdiction should not • Substantially affect outcome • Significantly affect result • So far as legal rules determine the outcome • Clone: • Federal Courts in diversity cases are effectively only another court of the state.

  5. Guaranty Trust Approach Significant Effect on Outcome? Yes No Apply Federal Apply State

  6. Two Quick Cases

  7. Cohen v. Beneficial Industrial • Issue? • State bond requirement in derivative actions • Decision • Apply state bond requirement • Note: D argued that FRCivP governed and said nothing about requiring bond

  8. Ragan v. Merchants Transfer FRCivP 3 Says Action Commenced State Law Says S/L Tolled Suit Filed Event + 2 Yrs Event Service Which Governs? What theory? Does this mean Erie trumps FRCivP?

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