Does federal law (specifically Rule 4(d)(1) of the Federal Rules of Civil Procedure) or state law govern the manner of service of process in a diversity jurisdiction case in federal district court?

A citizen of Ohio filed a complaint in the U.S. District Court for the District of Massachusetts, seeking damages for personal injuries sustained in a car accident in South Carolina. The defendant named was the executor of Louise Plumer Osgood's estate, a deceased Massachusetts resident. The plaintiff served the summons and complaint by leaving copies with the executor's wife at their residence, in accordance with Federal Rule 4(d)(1).

The executor responded with an answer, contending that the action could not proceed due to non-compliance with Massachusetts General Laws Chapter 197, Section 9. This state law mandates either in-hand service or filing of notice in the probate registry within one year of the executor providing bond. The executor argued that the plaintiff's method of service did not satisfy these state law requirements, potentially barring the lawsuit from moving forward.

The executor filed a motion for summary judgment in the District Court. The District Court granted this motion, basing its decision on precedents set in Ragan v. Merchants Transfer Co. and Guaranty Trust Co. v. York. The losing party then appealed to the Court of Appeals for the First Circuit. The Court of Appeals affirmed the District Court's ruling, determining that the conflict between state and federal rules pertained to a substantive matter. Subsequently, the Supreme Court granted certiorari to review the case, motivated by concerns that the lower court's decision posed a threat to the uniformity of federal procedure.

(Warren, C.J.)

Yes. Federal Rule of Civil Procedure 4(d)(1) governs the manner of service of process in diversity jurisdiction cases in federal district courts. The Federal Rules of Civil Procedure, including Rule 4(d)(1), are the standard against which the adequacy of service must be measured in federal diversity cases. This rule falls squarely within Congress's power to regulate matters in federal courts that are rationally capable of classification as procedural. The Erie doctrine does not act as a limitation on the Federal Rules of Civil Procedure. When a Federal Rule covers a particular situation, it must be applied unless it violates the Rules Enabling Act or constitutional restrictions. The constitutional provision for a federal court system inherently carries with it congressional authority to establish rules governing practice and pleading in those courts. This authority encompasses the power to regulate matters that can be rationally classified as either substantive or procedural. The adoption of Rule 4(d)(1) neither exceeds the congressional mandate in the Rules Enabling Act nor transgresses constitutional boundaries. Consequently, in federal diversity cases, the Federal Rules, not state law, control procedural matters such as service of process, ensuring uniformity and efficiency in federal court proceedings.

Concurrence (Harlan, J.) The Court has misconceived the constitutional premises of Erie and failed to adequately address past decisions. A more appropriate approach focuses on whether the choice of rule would substantially affect primary decisions respecting human conduct which our constitutional system leaves to state regulation. This analysis better aligns with the principles of federalism and the proper role of federal courts in interpreting state law. The majority's reasoning risks overextending federal authority in areas traditionally left to state governance.