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Supreme Court of the United States - 137 S. Ct. 1549
tl;dr:
Railroad employees who were injured by their employer may not sue in a state in which the railroad does not meet the standard for general jurisdiction of systematic and continuous contacts.Video Summary
Case Summary
BNSF Railway Co. v. Tyrrell was a 2017 Supreme Court case involving a dispute over personal jurisdiction between a railroad company and two plaintiffs who sued for injuries sustained while working for the railroad. The main issue was whether the railroad company was "at home" in Montana, where the legal action was filed.
Tyrrell, a South Dakota resident, sued BNSF in Montana state court under the Federal Employers' Liability Act (FELA), claiming he developed a knee condition from working in South Dakota, Iowa, and Minnesota. Nelson, a North Dakota resident, also sued BNSF in Montana state court under FELA, alleging he injured his back while working in Washington State. Neither claimed injuries or work-related activities in Montana.
BNSF was incorporated in Delaware and had its principal place of business in Texas. It operated railroad lines in 28 states, including Montana. BNSF moved to dismiss the suits for lack of personal jurisdiction, stating it was not "at home" in Montana, and the suits didn't relate to its activities there.
The Supreme Court ruled Montana courts lacked personal jurisdiction over BNSF for claims unrelated to activities in Montana, clarifying the scope of personal jurisdiction over corporations based on their connections with the forum state. The court applied a strict and narrow approach to general jurisdiction and acknowledged personal jurisdiction as a constitutional doctrine protecting defendants from being brought to court in distant or inconvenient forums. The Court emphasized that personal jurisdiction must align with federalism principles and respect the sovereignty and competence of other states and countries. The decision left open the possibility of a different result if the plaintiffs' claims were related to or arose out of BNSF's activities in Montana.
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The US Supreme Court reversed the Montana Supreme Court's decision to exercise personal jurisdiction over BNSF Railway Company, a Delaware corporation, in two lawsuits under the Federal Employers' Liability Act (FELA) for employee injuries. The US Supreme Court stated that the Fourteenth Amendment's Due Process Clause does not allow a state to bring an out-of-state corporation before its courts when the corporation is not "at home" in the state and the incident in question occurred elsewhere. The provision in Section 56 of FELA expands venue for a federal-court action beyond the limits of the 1888 Judiciary Act's general venue provision, but it does not affect personal jurisdiction. The Montana Supreme Court's interpretation of § 56 allowing state courts to exercise personal jurisdiction over a railroad defendant is not supported by previous cases or the legislative history of the provision.
Justice Sotomayor agrees that state courts lack personal jurisdiction over railroads under FELA, but disagrees with the Court's interpretation of the Due Process Clause and the "essentially at home" standard from Daimler AG v. Bauman. She believes that the Montana Supreme Court should conduct a fact-intensive analysis under the proper legal framework. Sotomayor concurs with Parts I and II of the Court's opinion but dissents from Part III and the judgment. She argues that the Court should follow International Shoe Co. v. Washington and consider whether a corporation's continuous operations in a state are substantial enough to justify general jurisdiction. The "at home" test from Daimler creates unfair outcomes and is not supported by precedent, according to Sotomayor.
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