Guaranty Trust Co. v. York
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The 3 confirmed adverse treatments are listed below. Byrd v. Blue Ridge Rural Electric Cooperative, Inc. recognized a federal interest in jury decision making that can outweigh a state procedural rule even when the result might differ; the Eastern District of Wisconsin criticized York's language about equitable remedies. The Second Circuit declined to extend that formulation to service on a foreign corporation. York's holding on state statutes of limitations in diversity suits remains intact.
50 later cases cite Guaranty Trust Co. v. York; 50 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Guaranty Trust Co. v. York?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Supreme Court held that a federal interest in jury decision making can outweigh the state procedure even when following federal practice might change the result, confining York's outcome inquiry.
Byrd v. Blue Ridge Rural Electric Cooperative, Inc. · Supreme Court of the United States · filed
The policy of uniform enforcement of state-created *538rights and obligations, see, e. g., Guaranty Trust Co. v. York, supra, cannot in every case exact compliance with a state rule12 — not bound up with rights and obligations— which disrupts the federal system of allocating functions between judge and jury.
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The Second Circuit declined to extend York's outcome inquiry to whether a foreign corporation could be served in federal court, holding that federal law governed that question.
Jaftex Corp. v. Randolph Mills, Inc. · Second Circuit · filed
Acknowledging a conflict in the cases, with the views of his colleagues being generally opposed, he yet thought the precedents following state law the weightier; additionally, applying Guaranty Trust Co. of New York v. York, 326 U.S. 99, 65 S.Ct. 1464, 89 L.Ed. 2079, 160 A.L.R. 1231, he held that if as a result of even procedural law, so-called, a plaintiff is barred from recovery in the state courts, application of the Erie principle bars recovery in the federal courts on the same claim. ... The learned judge’s suggestion that Jaftex could not recover in the federal courts because he could not do so in the state courts misses *514this point and the essential uniformity of procedure throughout the national court system.
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Criticized
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The district court called some of York's language about federal equitable remedies inconsistent with York's conclusion, although it applied the case's state law principle.
Houseware Sales Corp. v. Quaker Stretcher Co. · Eastern District of Wisconsin · filed
Some of the language in the Guaranty Trust company case seems to me somewhat inconsistent with the conclusion reached in that case.
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