01-1552, 01-2760 Park v. City of Chicago

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“We turn first to Ms. Park’s contention that the district court violated the mandates of Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), when it denied her motion in limine and thus declined to exclude the contested documents from trial pursuant to a sanction provision of the Illinois Record Act. In essence, Ms. Park submits that this state evidentiary statute should govern not only discovery but also issues of admissibility in this federal question litigation. We cannot accept this proposition. The Federal Rules of Evidence, not provisions of state law, govern the admissibility of evidence in federal court. See Fed. R. Evid. 101, 402. It is well-established that, generally, the rule in Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), requires federal courts to apply state substantive law ‘except in matters governed by the Federal Constitution or by acts of Congress.’ Erie, 304 U.S. at 78. Matters concerning the admissibility of evidence and matters of practice and procedure are governed by federal law, as long as those rules are procedural in character.

“Given these principles, the district court correctly rejected Ms. Park’s motion in limine seeking exclusion of the documents pursuant to the Illinois Record Act. The exclusion of documents as a sanction for nondisclosure is a subject for regulation by the federal court as a matter of procedure. Moreover, Ms. Park’s principal cause of action stems from Title VII, a federal statute that prohibits certain forms of discrimination in the workplace. Indeed, her claims arise exclusively under federal law. As we noted, in such a situation, Erie and its progeny do not bind the federal courts. As such, the Illinois Record Act, a state evidentiary statute, may not displace the Federal Rules of Evidence and the guidelines they establish concerning the admissibility of these documents in Ms. Park’s Title VII and sec. 1981 actions.”

Affirmed.

Appeals from the United States District Court for the Northern District of Illinois, Lefkow, J., Ripple, J.