Case Citator › Guaranty Trust Co. v. York

Guaranty Trust Co. v. York

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
326 U.S. 99
Decided
Confirmed treatments
4
Flagged citations read
39 of 39
Citing cases (total)
39
Treatment dates
1958–1973
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Guaranty Trust Co. v. York still requires federal diversity courts to honor state limitation periods that bar state-created claims. Its broader suggestion that every difference in outcome requires a federal court to follow state procedure has been limited.
More on how this was screened

All 39 flagged citations have been read; four limiting decisions are listed below. The Second Circuit later overruled the alternative ground of one of them, Jaftex Corp. v. Randolph Mills, Inc.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

39 later cases cite Guaranty Trust Co. v. York; 39 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

  • The Supreme Court held that a state rule assigning an immunity issue to a judge need not displace the federal court's jury practice merely because the choice could affect the result.

    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. Herron v. Southern Pacific Co., 283 U. S. 91. Thus the inquiry here is whether the federal policy favoring jury decisions of disputed fact questions should yield to the state rule in the interest of furthering the objective that the litigation should not come out one way in the federal court and another way in the state court.
    Read the full opinion on CourtListener →

  • The Second Circuit treated a foreign corporation's amenability to service as a federal procedural question despite a contrary state-law result; the court later overruled this alternative ground en banc in Arrowsmith v. United Press International.

    Jaftex Corp. v. Randolph Mills, Inc. · Second Circuit · filed

    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 this point and the essential uniformity of procedure throughout the national court system. ... Hence our conclusion is that the question whether a foreign corporation is present in a district to permit of service of process upon it is one of federal law governing the procedure of the United States courts and is to be determined accordingly.
    Read the full opinion on CourtListener →

  • The Supreme Court rejected an automatic use of York's outcome test where a valid Federal Rule of Civil Procedure governs service of process.

    Hanna v. Plumer · Supreme Court of the United States · filed

    Respondent, by placing primary reliance on York and Ragan, suggests that the Erie doctrine acts as a check on the Federal Rules of Civil Procedure, that despite the clear command of Rule 4 (d)(1), Erie and its progeny demand the application of the Massachusetts rule. ... The syllogism possesses an appealing simplicity, but is for several reasons invalid.
    Read the full opinion on CourtListener →

  • The court applied federal Rule 15(c) to allow an amended claim to relate back despite a state limitations objection, confining York's state-law rule where a federal procedural rule controlled.

    Applied Data Processing, Inc. v. Burroughs Corp. · District of Connecticut · filed

    On the one hand, we are told that a district court’s diversity jurisdiction must not be used to keep alive a right which has lapsed under state law. Guaranty Trust Co. of New York v. York, 326 U.S. 99, 65 S.Ct. 1464, 89 L. Ed. 2079 (1945). ... Here the issue is the timeliness of a claim rather than an entire action, but similar considerations support according supremacy to Rule 15(c).4
    Read the full opinion on CourtListener →

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