Opinion · Supreme Court of the United States

Woods v. Interstate Realty Co.

Woods v. Interstate Realty Co., 337 U.S. 535 (1949)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1949-06-20
Topic
general

How later courts describe this case

  • holding that "where a decision rests on two or more grounds, none can be relegated to the category of obiter dictum."
  • holding that a statute prohibiting certain persons from bringing suit in Mississippi under a statement prohibiting suits “in courts of this State” applied to Mississippi federal courts
  • holding that where federal jurisdiction is based on diversity of citizenship, federal courts cannot entertain a claim if the courts of the forum state could not entertain the same claim
  • holding diversity ease must be dismissed based on state statute that, by its terms, governed only proceedings in state court
  • holding diversity case must be dismissed based on state statute that, by its terms, governed only proceedings in state court
  • explaining that “where a decision rests on two or more grounds, none can be relegated to the category of obiter dictum”
  • noting that, where a reviewing court’s decision “rests on two or more” alternative grounds, either may support the court’s judgment
  • noting that in a diversity case premised on state law, when “one is barred from recovery in the state court, he should likewise be barred in the federal court’

Citator

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Authority status
pending
Cited by
494 opinions

Headnotes

  1. Civil Procedure — Erie Doctrine In a diversity action, a federal court must apply state law as the rules of decision, including state statutes and decisional law, and where state law closes the state courts to a particular suit, the federal court sitting in that state must likewise bar the action; a right which local law creates but does not supply with a remedy is no right at all for purposes of enforcement in a federal court in a diversity case. 337 U.S. 535, 537-538
  2. Civil Procedure — Effect of Prior Decisions Where a prior decision rests on two or more grounds, none of the grounds may be relegated to the category of obiter dictum; each independent basis of the decision is binding. 337 U.S. at 537
  3. Civil Procedure — Erie Doctrine For purposes of diversity jurisdiction, a federal court is in effect only another court of the state, and must apply the same substantive law that would be applied by the state courts, including state statutes of limitations, burden of proof rules, contributory negligence standards, conflict of laws rules, and rules governing accrual of causes of action, in order to avoid discrimination against citizens of the state in favor of those authorized to invoke diversity jurisdiction. 337 U.S. at 538