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Keywords

defendantstatutestatute of limitationscivil procedurerespondent
contractdefendantjurisdictionstatuteappealcitizenshipstatute of limitations

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Walker v. Armco Steel Corp., 446 U.S. 740, 100 S.Ct. 1978, 64 L.Ed.2d 659, 29 Fed.R.Serv.2d 493

Facts

The petitioner, a carpenter, was injured when a nail manufactured by the respondent fragmented and struck him in the eye. The complaint was filed in the United States District Court for the Western District of Oklahoma within the two-year statute of limitations, but service of process was not completed until after the limitations period and the 60-day service period had expired. The respondent moved to dismiss the case, arguing it was barred by the Oklahoma statute of limitations, which the District Court upheld.

According to the allegations of the complaint, petitioner, a carpenter, was injured on August 22, 1975, in Oklahoma City, Okla., while pounding a Sheffield nail into a cement wall.

Issue

Whether in a diversity action the federal court should follow state law or Rule 3 of the Federal Rules of Civil Procedure in determining when an action is commenced for the purpose of tolling the state statute of limitations.

The question whether state or federal law should apply on various issues arising in an action based on state law which has been brought in federal court under diversity of citizenship jurisdiction has troubled this Court for many years.

Rule

The Oklahoma statute of limitations requires that an action is not deemed commenced until service of summons on the defendant, and if the complaint is filed within the limitations period, it is deemed commenced from that date if service occurs within 60 days.

An action shall be deemed commenced, within the meaning of this article [the statute of limitations], as to each defendant, at the date of the summons which is served on him, or on a codefendant, who is a joint contractor or otherwise united in interest with him.

Analysis

The Court determined that Rule 3, which states that a civil action is commenced by filing a complaint, does not affect state statutes of limitations. The Oklahoma statute was found to be an integral part of the state's statute of limitations, and since service was not completed within the required time frame, the action was barred. The Court emphasized that the policies behind the statute of limitations, including the need for actual notice to the defendant, were not served by applying the federal rule.

In our view, in diversity actions Rule 3 governs the date from which various timing requirements of the Federal Rules begin to run, but does not affect state statutes of limitations.

Conclusion

The Supreme Court affirmed the decision of the lower courts, holding that the action was barred by the Oklahoma statute of limitations due to the failure to serve the defendant within the required time frame.

The judgment of the Court of Appeals is Affirmed.

Who won?

The respondent prevailed in the case because the Court upheld the application of the Oklahoma statute of limitations, which barred the action due to insufficient service of process.

The District Court dismissed the complaint as barred by the Oklahoma statute of limitations, holding that § 97 was an integral part of the Oklahoma statute of limitations.

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