Case BriefCiv Pro, BauerState law in federal courts: procedural questions2/7/15Identity of CaseGuaranty Trust Co. of New York v. York, 326 U.S. 99 (1945)Page 921 of the casebookSummary of Facts/Procedural HistoryYork is a representative of a class action that brings civil suit against Guaranty Trust co. Diversity jurisdiction, federal court, etc. Guaranty’s defense was basedon the fact that the statute of limitations had passed on York’s claim (state-based statute of limitations, state-based claim). Federal court hears it anyways, Second Cir. Affirms, SCOTUS affirms. Statement of the IssueAre the statute of limitations laws of a state a substantive right which the federal gov’t is entitled to follow or a procedural right which they do not? HoldingStatute of limitations represent a substantive right not to be sued after a certain amount of time, protectfrom surprise attacks, etc. Although they have some procedural effects, they are mostly substantive. Federal courts therefore must follow them. ReasoningNot doing so would conflict with the goal of horizontal uniformity that Erie stands for. “The operation of a double system of conflicting laws in the same State is plainly hostile to the reign of law.”
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