Berk v. Choy
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Berk v. Choy and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Berk v. Choy.
The Supreme Court ruled that Delaware's affidavit requirement for medical malpractice suits does not apply in federal court. The Court determined that Federal Rule of Civil Procedure 8 governs the requirements for filing a complaint, displacing the state law. The decision emphasizes the procedural nature of federal rules over state substantive requirements.
Holding
The single most important “bottom line” of what the Court decided in Berk v. Choy.
The Court held that Delaware’s affidavit law does not apply in federal court.
Constitutional Concepts
These are the Constitution-related themes that appear in Berk v. Choy. Click a concept to see other cases that involve the same idea.
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Why Preemption is relevant to Berk v. Choy
The case involves the preemption of state law by federal procedural rules.
Syllabus excerpt (verbatim)Delaware’s affidavit law does not apply in federal court.
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Why Procedural Due Process is relevant to Berk v. Choy
The decision addresses the procedural requirements for filing a lawsuit in federal court.
Syllabus excerpt (verbatim)Rule 8 prescribes the information a plaintiff must present about the merits of his claim at the outset of litigation.
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Why State–Federal Power is relevant to Berk v. Choy
The case examines the allocation of authority between state procedural requirements and federal court rules.
Syllabus excerpt (verbatim)When a plaintiff brings a state-law claim in federal court, the court faces a choice-of-law problem: whether to apply state or federal law.
Key Quotes
Short excerpts from the syllabus in Berk v. Choy that support the summary and concepts above.
Delaware’s affidavit law does not apply in federal court.
Rule 8 establishes 'implicitly, but with unmistakable clarity,' that evidence of the claim is not required.
This Court has consistently rejected efforts by lower federal courts to require more information than Rule 8 requires.
