Walker v. Armco Steel Corp.

446 U.S. 740, 100 S. Ct. 1978 (1980)

 

RULE:

The Federal Rules of Civil Procedure are not to be narrowly construed in order to avoid a collision with state law. The Federal Rules should be given their plain meaning.

FACTS:

An Oklahoma resident was injured by the shattering of a nail he had attempted to pound into a wall, claiming that the nail was defective because of the out-of-state manufacturer's negligence in manufacture and design. The injured person brought suit against the manufacturer within the state statute of limitations, but service was not made until more than 60 days after expiration of the limitations period. Under Okla. Stat. tit. 12, § 97 (1971), service was too late, but service would have been timely under Fed. R. Civ. P. 3. The district court dismissed the complaint because the Oklahoma tolling statute was an integral part of its statute of limitations. The court of appeals agreed, and the Supreme Court affirmed.

ISSUE:

Should the Oklahoma statute of limitations apply as opposed to the Federal rule?

ANSWER:

Yes.

CONCLUSION:

The Court reviewed prior rulings concerning statutes of limitation, and held that under those rulings, the state tolling provisions applied. The Court noted that in diversity actions, Rule 3 governed the date on which various timing requirements of the Federal Rules began to run, but it did not affect state statutes of limitation. On the other hand, the state statute was a statement of a substantive decision by the state that actual service on the defendant was an integral part of the several policies served by the statute of limitations. Rule 3 and Okla. Stat. tit. 12, § 97 (1971) therefore each controlled its own intended sphere of coverage without conflict.

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