Brown v. Pacific Coast Coal Co.
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241 U.S. 571 (1916)
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U.S. Supreme Court
Brown v. Pacific Coast Coal Co., 241 U.S. 571 (1916)
Brown v. Pacific Coast Coal Company
Argued March 14, 1916
Decided June 12, 1916
241 U.S. 571
In a case where its jurisdiction rests on diverse citizenship, it is the duty of the federal court to follow the applicable decisions of the state court.
The Supreme Court of the Washington, having in an earlier and similar case to the one pending in the federal court, decided that, under the Mining Act of that state, there is a duty on the mine owner to supply ventilation that will prevent accumulations of gas, which duty cannot be delegated, and that the gas tester is a representative of the principal, and not a fellow servant of other employees engaged in mining, held that it was the duty of the circuit court of appeals to have followed that ruling and to hold that the gas tester was not a fellow servant.
Even though, in the earlier case in the state court, the words of the state supreme court might have been obiter dicta, if they stated the principle of the decision, it was the duty of the federal court to follow them even though the state court may have previously held otherwise.
214 F. 255 reversed; 211 F. 869 affirmed.
The facts, which involve the validity of a judgment of the circuit court of appeals in an action for personal injuries and the duty of the federal court to follow the applicable decisions of the state court in such cases, are stated in the opinion.