Berk v. Choy

CourtSupreme Court of the United States
DecidedJanuary 20, 2026
Docket24-440
StatusPublished

This text of Berk v. Choy (Berk v. Choy) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Berk v. Choy, (U.S. 2026).

Opinion

(Slip Opinion) OCTOBER TERM, 2025 1

Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

BERK v. CHOY ET AL.

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 24–440. Argued October 6, 2025—Decided January 20, 2026

Delaware law provides that a plaintiff may not sue for medical malprac- tice unless a medical professional attests to the suit’s merit in an “af- fidavit of merit” that “accompanie[s]” the plaintiff’s complaint. Del. Code, Tit. 18, §6853(a)(1). Petitioner Harold Berk sued Dr. Wilson Choy and Beebe Medical Center in federal court for medical malprac- tice under Delaware law, but failed to provide the affidavit required by §6853. Berk argued that §6853 is not enforceable in federal court be- cause it is displaced by the Federal Rules of Civil Procedure. The Dis- trict Court dismissed Berk’s lawsuit for failure to comply with Dela- ware’s affidavit law. The Third Circuit affirmed. Held: Delaware’s affidavit law does not apply in federal court. Pp. 3–11. (a) 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. The Rules of Decision Act directs federal courts to apply state substantive law unless the Constitution, a treaty, or a statute other- wise requires or provides. 28 U. S. C. §1652. The Rules Enabling Act, which authorizes the Supreme Court to adopt uniform rules of proce- dure for district courts, provides for the application of federal law. §2072(a). So, when a valid Federal Rule of Civil Procedure is on point, it displaces contrary state law even if the state law would qualify as substantive under Erie R. Co. v. Tompkins, 304 U. S. 64. The analysis is straightforward: The Court first asks whether a Federal Rule an- swers the disputed question. If a Federal Rule does, it governs, unless it “exceeds statutory authorization or Congress’s rulemaking power.” Shady Grove Orthopedic Associates, P. A. v. Allstate Ins. Co., 559 U. S. 393, 398. Pp. 3–4. 2 BERK v. CHOY

(b) Here, Rule 8 answers the disputed question whether Berk’s law- suit may be dismissed because his complaint was not accompanied by an affidavit. Rule 8 prescribes the information a plaintiff must present about the merits of his claim at the outset of litigation: “a short and plain statement of the claim showing that [he] is entitled to relief.” Fed. Rule Civ. Proc. 8(a)(2). By requiring no more than a statement of the claim, Rule 8 establishes “implicitly, but with unmistakable clar- ity,” Hanna v. Plumer, 380 U. S. 460, 470, that evidence of the claim is not required. Rule 12 reinforces the point by providing only one ground for dismissal based on the merits—“failure to state a claim upon which relief can be granted,” Rule 12(b)(6)—and prohibiting courts from con- sidering “matters outside the pleadings” when evaluating whether a plaintiff has stated a claim, Rule 12(d). The court instead asks only whether the complaint’s factual allegations, if taken as true, “state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U. S. 544, 570. This Court has consistently rejected ef- forts by lower federal courts to require more information than Rule 8 requires. Delaware’s law and Rule 8 thus give different answers to the question whether Berk’s complaint can be dismissed as insufficient be- cause it was unaccompanied by an affidavit. Defendants offer a workaround: They rewrite Delaware’s law. After defendants’ edits, the Delaware law is no longer a pleading require- ment but a free-floating evidentiary requirement that can serve as the basis for an early dismissal. But that requirement could not be en- forced under the Federal Rules. Defendants concede that the absence of an affidavit is not grounds for dismissal under Rule 12(b)(6). And Rule 56 already prescribes the mechanism for putting a plaintiff to his proof: a motion for summary judgment. Finally, defendants’ argument that Rule 11’s proviso concerning af- fidavits incorporates state affidavit laws like §6853 fails because the proviso cannot be read to address affidavits from third parties. Pp. 4– 10. (c) Because Rule 8 and §6853 answer the same question, Rule 8 gov- erns so long as it is valid under the Rules Enabling Act, which requires that Federal Rules be procedural rather than substantive. 28 U. S. C. §2072(b). Rule 8 is valid under the Rules Enabling Act because it “re- ally regulates procedure.” Sibbach v. Wilson & Co., 312 U. S. 1, 14. Defendants argue that determining whether a Rule is valid under the Rules Enabling Act requires also asking whether the displaced state law is substantive, but “the substantive nature of [a state] law, or its substantive purpose, makes no difference” to the analysis of a Federal Rule’s validity. Shady Grove, 559 U. S., at 409. Pp. 10–11. Reversed and remanded. Cite as: 607 U. S. ___ (2026) 3

BARRETT, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, ALITO, SOTOMAYOR, KAGAN, GORSUCH, and KAVANAUGH, JJ., joined. JACKSON, J., filed an opinion concurring in the judgment. Cite as: 607 U. S. ____ (2026) 1

Opinion of the Court

NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors.

SUPREME COURT OF THE UNITED STATES _________________

No. 24–440 _________________

HAROLD R. BERK, PETITIONER v. WILSON C. CHOY, ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT [January 20, 2026]

JUSTICE BARRETT delivered the opinion of the Court. The cost of malpractice insurance for doctors and hospi- tals has significantly increased in some areas of the coun- try. In response, several States have imposed a screening mechanism on malpractice suits, requiring plaintiffs to sub- mit an affidavit from a medical professional attesting to the suit’s merit. We consider whether Delaware’s affidavit re- quirement applies in federal court and hold that it does not. I While on a trip to Delaware, Harold Berk fell out of bed. According to his complaint, he was taken by ambulance to a hospital owned by Beebe Medical Center, Inc., where an X ray revealed a fractured ankle. Dr. Wilson Choy recom- mended that Berk be fitted with a protective boot. The fitting did not go well. Hospital employees forced Berk’s leg into the boot, twisting his fractured ankle. Still, Dr. Choy did not immediately order another X ray; he told Berk to keep weight off his ankle, proposed a follow-up ap- pointment in two weeks, and sent Berk on his way.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Detroit Timber & Lumber Co.
200 U.S. 321 (Supreme Court, 1906)
Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
Fidelity Union Trust Co. v. Field
311 U.S. 169 (Supreme Court, 1941)
Sibbach v. Wilson & Co.
312 U.S. 1 (Supreme Court, 1941)
Mississippi Publishing Corp. v. Murphree
326 U.S. 438 (Supreme Court, 1946)
Woods v. Interstate Realty Co.
337 U.S. 535 (Supreme Court, 1949)
Cohen v. Beneficial Industrial Loan Corp.
337 U.S. 541 (Supreme Court, 1949)
Hanna v. Plumer
380 U.S. 460 (Supreme Court, 1965)
Walker v. Armco Steel Corp.
446 U.S. 740 (Supreme Court, 1980)
Burlington Northern Railroad v. Woods
480 U.S. 1 (Supreme Court, 1987)
Hallstrom v. Tillamook County
493 U.S. 20 (Supreme Court, 1990)
Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Tellabs, Inc. v. Makor Issues & Rights, Ltd.
551 U.S. 308 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Hall v. SOROURI
996 A.2d 793 (Supreme Court of Delaware, 2010)
Gasperini v. Center for Humanities, Inc.
518 U.S. 415 (Supreme Court, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
Berk v. Choy, Counsel Stack Legal Research, https://law.counselstack.com/opinion/berk-v-choy-scotus-2026.