Camden & Suburban Railway Co. v. Stetson
Headline: Allows federal courts in New Jersey to order surgical examinations of injured plaintiffs under a state law, letting defendants obtain medical exams when no federal statute conflicts with the state rule.
Holding: When a State’s statute authorizes a surgical examination of an injured plaintiff and no federal law conflicts, federal courts sitting in that State may order the examination under section 721 of the Revised Statutes.
- Allows defendants in federal court to request surgical exams when state law permits.
- Federal courts must follow a state’s evidence rules if no federal conflict exists.
- Injured plaintiffs in such states may be required to undergo court-ordered physical exams.
Summary
Background
This case involved an injured plaintiff and a defendant who asked a federal court sitting in New Jersey to order a surgical examination of the plaintiff. At common law federal courts have no inherent power to force such an examination, as discussed in Union Pacific Railway v. Botsford, but New Jersey had a statute authorizing such examinations and section 721 of the Revised Statutes says federal courts should apply state laws as rules of decision when appropriate.
Reasoning
The central question was whether a federal court in the State must follow a state law that allows a surgical exam. The Court explained that section 721 brings applicable state laws into federal trials unless the Constitution, treaties, or a federal statute say otherwise. Because the New Jersey statute did not conflict with federal statutes (including rules about oral examination in open court), the Court held federal courts sitting in New Jersey may order the examination under the state law applied through section 721.
Real world impact
The ruling means that where a State has a statute permitting a medical examination and no federal law conflicts, defendants in federal court in that State can seek court-ordered physical or surgical exams of plaintiffs. The decision depends on the existence of a state statute; it does not create a general federal power to order exams everywhere. The Court noted that the plaintiff’s citizenship at the time of injury was not material so long as the court had jurisdiction when the action began.
Dissents or concurrances
Justice Harlan dissented from the Court’s answer to the question, though the main opinion speaks for the majority.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?