Sampson v. Channell
United States Court of Appeals for the First Circuit
110 F.2d 754 (1940)
Albert Sampson (plaintiff) was seriously injured in Maine when his vehicle collided with one driven by Channell's (defendant) testator, and he sued for negligence in federal district court in Massachusetts. Sampson asked the court to apply Massachusetts law, which placed the burden on Channell to prove Sampson's contributory negligence, but the court instead applied Maine law, which put the burden on Sampson to disprove his own contributory negligence. The jury found for Channell on that issue, and Sampson appealed.
Whether a federal district court sitting in diversity must apply the substantive law of the forum state regarding the burden of proof for contributory negligence.