Recognizing a conflict between the goals of uniform federal procedure and of uniform outcome in state and federal forums, the Supreme Court in <em>Hanna v. Plumer</em> removed the Federal Rules from the purview of the <em>Erie</em> doctrine and announced a separate standard more solicitous of federal procedural uniformity. The <em>Hanna</em> Court, however, confounded lower courts and legal scholars by failing to overrule <em>Ragan v. Merchants Transfer & Warehouse Co.</em>, decided under the <em>Erie</em> doctrine and in apparent conflict with the Court's new perspective on the Federal Rules. Legal commentators debated <em>Ragan's</em> continued vitality, lower courts split, and both groups pleaded for Supreme Court guidance. The Supreme Court answered their pleas in <em>Walker v. Armco Steel Corp.</em>, where the Court, relying on <em>Ragan</em>, held that state commencement provisions, rather than the Federal Rule, toll state statutes of limitations in diversity of citizenship cases. This article evaluates the <em>Walker</em> case in the context of <em>Erie</em> doctrine cases preceding it, and of later federal cases attempting to follow it. First, this article examines the facts and reasoning in <em>Walker</em>. Next, the article reviews the case law leading up to <em>Walker</em>, and then focuses on the flaws in the <em>Walker</em> analysis. After critically evaluating <em>Walker</em>, the article examines a Ninth Circuit decision interpreting <em>Walker</em>. Last, this article suggests that lower courts narrowly interpret <em>Walker</em>, restricting its scope to cases involving Federal Rule 3.
Theresa B. Doyle, Walker v. Armco Steel Corporation: The Jurisprudence of Federal Rule 3, 5 SEATTLE U. L. REV. 307 (1982).