Hanna v. Plumer
United States Supreme Court
380 U.S. 460 (1965)
After a fatal car accident, Hanna (plaintiff) sued the deceased driver's estate, represented by executor Plumer (defendant), in federal court based on diversity jurisdiction. Hanna served process on Plumer's wife in a manner that fully satisfied the Federal Rules of Civil Procedure, but a Massachusetts substantive statute required personal service on an executor as a precondition to the estate's liability. Plumer moved for summary judgment based on this state-law personal-service requirement, and the district court and First Circuit agreed the claim was barred. The Supreme Court granted certiorari.
Whether a plaintiff who serves a defendant properly under the Federal Rules of Civil Procedure may proceed with a state-law claim that would otherwise require a different, unsatisfied method of service to establish liability.