P was injured in an automobile accident in IN that she claimed was caused by D.
P filed suit in federal court in IL. D moved for an order requiring P to submit to a physical examination pursuant to FRCP 35(a).
District court ordered the exam, but P refused to comply arguing that the federal rule was invalid since it contravened IL state law.
Procedural History:
District court held P in contempt, motion under FRCP 35(a) valid.
COA affirmed, held P in contempt, motion under FRCP 35(a) valid.
SCOTUS reversed and remanded, P cannot be held in contempt but motion under FRCP 35(a) still valid.
Issues:
For federal cases sitting in diversity, how should a federal district court resolve a potential conflict between one of the Federal Rules of Civil Procedure and state law?
Holding/Rule:
To resolve a potential conflict between one of the Federal Rules of Civil Procedure and state law, a federal district court should determine whether the rule can be rationally classifiable as procedural and that it does not abridge, enlarge, or modify a substantive right.
Reasoning:
The Rules Enabling Act was purposefully restricted in its operation to matters of pleading and court practice and procedure. The court should not abridge, enlarge, or modify substantive rights.
Substantive rights do not mean "important" or "substantial" rights; substantive rules define the standards of conduct applicable to everyday life, while procedural rules specify the manner or means through which claims arising under the substantive law may be adjudicated.
The test must be whether a rule really regulates procedure (the judicial process for enforcing rights and duties recognized by substantive law and for justly administering remedy and redress for disregard or infraction of them).
The challenged rules comport with the policy of uniformity Congress sought to introduce in the federal system.
Dissent:
I deem a requirement as to the invasion of the person to stand on a very different footing from questions pertaining to the discovery of documents, pre-trial procedure and other devices for the expeditious, economic, and fair conduct of litigation.
