Walker v. Armco Steel Corp

In Walker v. Armco Steel Corp., 446 U.S. 740, 749, 100 S.Ct. 1978, 1984, 64 L.Ed.2d 659 (1980), the Supreme Court upheld the application of Oklahoma's tolling statute, which required actual service of process, in lieu of Fed.R.Civ.P. 3, which provided that a civil action could be commenced by filing a complaint with the court. See Armco Steel, 446 U.S. at 742-44, 100 S.Ct. at 1981-82. The Court noted the state's policy interest in enforcing its statute of limitations and in deferring tolling until a defendant had actual notice of a suit. See id. at 751, 100 S.Ct. at 1985. On this basis, the Court reasoned that the Oklahoma statute was a "statement of a substantive decision by that state," forming an " 'integral' part of the several policies served by the statute of limitations." Id. at 751-52, 100 S.Ct. at 1985-86. The Court concluded that "federal Rule 3 does not replace such policy determinations," but, rather, exists "side by side" with the state statute, "each controlling its own intended sphere of coverage without conflict." Id. at 752, 100 S.Ct. at 1986.