In the instant decision the federal district court determined that it was not bound by a state rule which directed dismissal of actions involving the internal affairs of foreign corporations. In light of the "equal protection" guidelines laid down by Erie R. R. v. Tompkins and Hanna v. Plumer in order to ascertain the applicability of state law in diversity cases, significant questions are raised by the court's "substance-procedure" approach and its assertion that the area covered by the state rule had been pre-empted by the federal doctrine of "forum non conveniens" embodied in section 1404(a) of the Judicial Code.
Federal Procedure: Erie-Hanna Rule Held Not to Compel Federal Application of State Internal Affairs Doctrine,
1966 Duke Law Journal
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