The Court explained that the Swift doctrine represented an unconstitutional invasion by the federal courts into the powers “reserved by the Constitution to the several states.” Id. at 79-80, 58 S.Ct. at 823. However, the holding in Erie did not destroy all types of federal common law. Since Erie, the Supreme Court “has recognized the need and authority in some limited areas to formulate what has come to be known as ‘federal common law.’ ” Texas Indus., Inc. v. Radcliff Materials, Inc., 451 U.S. 630, 640, 101 S.Ct. 2061, 2067, 68 L.Ed.2d 500 (1981). In particular, federal courts have created and applied federal common law when necessary to protect certain “uniquely federal interests.” Boyle v. United Technologies Corp., 487 U.S. 500, 504, 108 S.Ct. 2510, 2514, 101 L.Ed.2d 442 (1988) (<HOLDING>); see also United States v. Kimbell Foods,
holding that there was a triable issue of fact whether a defendant who applied a sprayon fireproofing material was an agent for the manufacturer of the material and thus whether plaintiff is in privity with the manufacturer recognizing that courts disagree whether federal common law or state law governs the interpretation of negotiated settlement agreement holding that federal law governs res judicata effect of an earlier federal judgment based on federal law holding that federal common law governs the tort liability of a helicopter manufacturer to a deceased pilot where the manufacturer supplies the helicopters to the federal government holding that federal common law governs equitable remedies available under erisa