Sibbach v. Wilson & Company
SCOTUS - 1941
- 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.
- 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.
- 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?
- 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.
- 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.
- 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.