## Facts

- Walker, an Oklahoma resident, alleged he was injured on August 22, 1975, by a defective nail manufactured by Armco Steel Corporation.
- Walker filed a negligence action in federal district court in Oklahoma on August 19, 1977, within Oklahoma’s two-year limitations period for personal injury claims.
- Armco was not served with process until December 1, 1977.
- Oklahoma law required service of summons to “commence” an action for limitations purposes, with a rule deeming the action commenced on the filing date only if service occurred within 60 days after filing.
- Service occurred after both the two-year period and the 60-day window.

## Issues

1. In a diversity action, whether Federal Rule of Civil Procedure 3 (commencement upon filing) governs tolling of a state statute of limitations, or whether the state’s service-based commencement rule controls.

## Decision

- The Supreme Court affirmed the dismissal of the action as time-barred.
- The Court held that Oklahoma’s service-based commencement rule governed tolling of the state statute of limitations in federal diversity court.
- The Court concluded Rule 3 did not directly conflict with, and therefore did not displace, Oklahoma’s limitations/tolling scheme.

## Legal Principles

- In diversity cases, federal courts apply state statutes of limitations and state tolling rules that are integral to the limitations scheme.
- Federal Rule of Civil Procedure 3 is not sufficiently broad to determine when a state statute of limitations is tolled; it primarily sets the start date for timing requirements within the Federal Rules.
- Absent a direct conflict between a Federal Rule and state law, the state rule applies under Erie principles to prevent different outcomes based solely on the choice of federal versus state forum.
- A state rule tying commencement to service may reflect substantive policies of limitations law, including notice to defendants and repose, and thus must be applied in diversity actions.

## Conclusion

Because Oklahoma conditioned tolling of its limitations period on timely service (with a limited grace period), and Rule 3 did not conflict with that scheme, the federal diversity action was barred when service was not completed within the time allowed by state law.


Walker v. Armco Steel Corp., 446 U.S. 740 (1980)