This is not the outcome-determinative test used
in Guaranty Trust Co. v. York, 326 U.S. 99 (1945). There the court
appeared to ask whether, in the middle of the case, shifting between
the federal common law rule and the state rule would make a difference
to how the case turned out. The question is instead whether the
difference would lead to ex ante forum shopping.
The
question is whether the difference would lead to forum shopping in
general, not in the particular case. Would a plaintiffs in
diversity/alienage cases (or cases with supplemental jurisdiction
actions) in general choose, or avoid, federal court due to the
difference? Would defendants such cases in general choose to remove, or
decline to remove, due to the difference?
Notice that now the
concern is no longer about state interests. The state that created the
rule does not care whether it is used in federal court. It has not
bound up its rule with its cause of action. But the twin aims could
still recommend that the federal court use the rule that would be used
by a forum state court. Notice as well that the issue is now uniformity
with a forum state court, not with the state that created the cause of
action. So if a federal court in New York is entertaining a
Pennsylvania cause of action, the twin aims recommend uniformity with a
New York state court, not respect for Pennsylvania interests.
The
inequitable administration of the laws test is closely related. The
idea is that it would be inequitable to have different procedural rules
apply to two cases simply because one happened to be a diversity case
(and so could be brought in federal court) and another wasn’t. In
general if there is the likelihood of forum shopping a court will also
find that there is an inequitable administration of the laws problem. I
discuss the inequitable administation of the laws test more fully in my
twin aims article (pp. 1896-1900).