Erie Doctrine: State Trial Court Rulings Provide Guidance But Are Not Controlling Unless They Are Treated As Precedents within the State — [Generally] They Are “At Most Persuasive, But … Not Binding on a Federal Court”

Amaral Enters. Llc v. Gian, 2019 U.S. Dist. LEXIS 101269 (D. Mass. June 18, 2019):

Footnote 6.  When a federal trial court sits in diversity, "[s]tate trial court rulings provide guidance but are not controlling unless they are treated as precedents within the state itself." In re New Motor Vehicles Canadian Export Antitrust Litig., 350 F. Supp. 2d 160, 169 (D. Me. 2004) (citing 19 Charles A. Wright, Arthur R. Miller & Edward Cooper, Federal Practice & Procedure § 4507, at 96 (1982)); see also In re PHC, Inc. Shareholder Litig., 894 F.3d 419, 428 (1st Cir. 2018) (a federal court sitting in diversity and faced with an issue of first impression should "'consult the types of sources that the state's highest court would be apt to consult, including analogous opinions of that court, decisions of lower courts in the state, precedents and trends in other jurisdictions, learned treatises, and considerations of sound public policy'" (quoting Butler v. Balolia, 736 F.3d 609, 613 (1st Cir. 2013)); O'Connor v. Oakhurst Dairy, 851 F.3d 69, 72 (1st Cir. 2017) (noting that a state trial court decision is at most persuasive, but is not binding on a federal court).

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