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Appellate Practice

Jun. 8, 2000

Cooperative Federalism

Practitioner: Appellate Law By James C. Martin and Benjamin G. Shatz Every lawyer knows that Erie Railroad v. Tompkins, 304 U.S. 64, 78 (1938), held that there is no general federal common law and that federal courts exercising diversity jurisdiction must apply applicable substantive state law. But how does a federal court apply state law when faced with a state-law issue of first impression?

James C. Martin

Partner Reed Smith LLP

Phone: (213) 457-8002

Email: jcmartin@reedsmith.com

James is in the firm's Appellate Group, resident in the Los Angeles and Pittsburgh offices. He is certified as specialists in appellate law by the California State Bar Board of Legal Specialization.

Benjamin G. Shatz

Partner Manatt, Phelps & Phillips LLP

Appellate Law (Certified), Litigation

Email: bshatz@manatt.com

Benjamin is a certified specialist in appellate law who co-chairs the Appellate Practice Group at Manatt in the firm's Los Angeles office. Exceptionally Appealing appears the first Tuesday of the month.

Every lawyer knows that Erie Railroad v. Tompkins, 304 U.S. 64, 78 (1938), held that there is no general federal common law and that federal courts exercising diversity jurisdiction must apply applicable substantive state law. But how does a federal court apply state law when faced with a state-law issue of first impression?

One approach, of course, is simply to abstain and wait for a state court determination of the issue. But abstention can be an unsatisfying and awkward s...

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