Law School Case Brief
Godin v. Schencks - 629 F.3d 79 (1st Cir. 2010)
Whether a federal rule is valid under the Rules Enabling Act, 28 U.S.C.S. § 2072, depends not on the federal rule alone, but also on the nature of the state rule it seeks to displace. The critical question is not whether the state law at issue takes the form of what is traditionally described as substantive or procedural, but rather whether the state law actually is part of a state's framework of substantive rights or remedies. This inquiry under the Rules Enabling Act may well bleed back into the inquiry of whether a federal rule is sufficiently broad to control the issue before the court. This is so because a federal rule cannot govern a particular case in which the rule would displace a state law that is procedural in the ordinary use of the term but is so intertwined with a state right or remedy that it functions to define the scope of the state-created right. To avoid such a result, when a federal rule appears to abridge, enlarge, or modify a substantive right, federal courts must consider whether the rule can reasonably be interpreted to avoid that impermissible result.
The former principal (Godin) of the Fort O'Brien Elementary School in Machiasport, Maine, brought suit against the Machiasport School Department Board of Directors ("Machiasport") alleging a violation of her due process rights. She also sued three individual school system employees who had separately stated in meetings with officials their views that Godin had acted abusively toward students at the school. Plaintiff brought state law claims that these allegations were defamatory and led the school system to terminate her employment. The school system said her job was terminated due to budgetary shortfalls. The defendants filed a special motion to dismiss under Maine's anti-SLAPP statute, Me. Rev. Stat. tit. 14, § 556. The statute created a special process by which a defendant could move to dismiss a claim arising from exercise of the right of petition under either the United States or Maine Constitution. The district court held that the anti-SLAPP statute conflicted with Fed. R. Civ. P. 12 and 56 and so did not apply in federal court. Because the district court denied the motion, the individual defendants sought interlocutory review.
Was it proper to deny the special motion to dismiss under Maine's anti-SLAPP statute?
The appellate court reversed the district court's order, and remanded so that the district court may consider the merits of the individual defendants' special motion to dismiss. The anti-SLAPP statute had to be applied because neither Fed. R. Civ. P. 12(b)(6) nor Fed. R. Civ. P. 56 was meant to control the particular issues and the dual purposes of Erie were best served by enforcement of Me. Rev. Stat. tit. 14, § 556 in federal court. The court also noted that it had jurisdiction over the interlocutory appeal because the ruling on the disputed issue was conclusive, distinct from the merits of the action, not so intertwined with factual issues as to make it highly unlikely to affect or even to be consequential to anyone aside from the parties, and raised an important issue of law weightier than the societal interests advanced by the ordinary operation of final judgment principles.
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