Salve Regina College v. Russell

Summary

The Court, in an opinion by Justice Blackmun, held that federal courts of appeals must review district courts' determinations of state law de novo, including predictions about unsettled state law. Independent review promotes decisional accuracy, doctrinal coherence, and the Erie doctrine's goals of discouraging forum shopping and avoiding inequitable administration of the laws. The Court reversed and remanded because the First Circuit deferred to the District Court's local expertise. Chief Justice Rehnquist, joined by Justices White and Stevens, dissented, arguing that appellate courts may sensibly give special weight to an experienced local district judge's assessment of unsettled state law without abandoning independent judgment, and that the First Circuit had done no more than that.