Guaranty Trust Co v York

1945

Venue: SCOTUS

Facts: Something about misrepresentation and breach of trust.

Posture: Suit in diversity. NY law governed, and defendant invoked the NY statute of limitations. Plaintiffs said the statute of limitations didn't bar the suit because it was on the "equity" side of federal court, where strict adherence to such things is nt required. 2nd Cir. rules that the suit is not barred.

Issue: When a state action is barred by the statute of limitations, can a federal court hear the case on diversity grounds?

Holding: No. Reversed.

Rule: When federal jurisdiction is based solely on diversity, the legal rules applied should be the same as they would have been in state court.

Reasoning: The question isn't just whether this is "procedural," it's whether it has significant bearing on the outcome. It doesn't matter whether you characterize something as "substantive" or "procedural;" the important ting is the policy that we want outcomes governed by the same rules of law. The "outcome-determinative" test, in other words.

Dicta: