The Supreme Court’s decision in Shady Grove Orthopedic Associates, P.A. v. Allstate Ins. Co., 130 S. Ct. 1431 (2010) does little to clarify the application of the Erie Doctrine. While many courts endeavor to apply and follow Erie, the classification of statutes and rules as “substantive” or “procedural” is far from uniform. In a plurality … Continue Reading