BNSF Railway Co. v. Tyrell
137 S.Ct. 1549 (2017)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The Federal Employers’ Liability Act (FELA), §56, is a venue statute that does not grant state courts personal jurisdiction over railroads. The exercise of general personal jurisdiction by a state court over a non-resident corporation must comply with the Fourteenth Amendment's Due Process Clause, which requires the corporation's affiliations with the state to be so continuous and systematic as to render it 'essentially at home' there.
Facts:
- Robert Nelson, a resident of North Dakota, was an employee of BNSF Railway Company (BNSF).
- Brent Tyrrell, whose estate was represented by South Dakota resident Kelli Tyrrell, was also a BNSF employee.
- Nelson alleged he sustained knee injuries, and Tyrrell alleged her husband developed fatal cancer from chemical exposure, due to their work for BNSF.
- Neither Nelson’s injury nor Brent Tyrrell's alleged exposure occurred in Montana, and neither man appears to have ever worked for BNSF in Montana.
- BNSF is incorporated in Delaware and maintains its principal place of business in Texas.
- At the time of the lawsuits, BNSF operated over 2,000 miles of railroad track in Montana and employed approximately 2,100 workers there.
- BNSF’s presence in Montana accounted for about 6% of its total track mileage and less than 5% of its total workforce.
Procedural Posture:
- Robert Nelson sued BNSF in a Montana state trial court under FELA.
- Kelli Tyrrell filed a separate FELA lawsuit against BNSF in a Montana state trial court.
- BNSF moved to dismiss both actions for lack of personal jurisdiction.
- The trial court granted BNSF's motion to dismiss in Nelson's case but denied it in Tyrrell's case.
- The cases were consolidated on appeal before the Montana Supreme Court, the state's highest court.
- The Montana Supreme Court reversed the dismissal in Nelson's case and affirmed the denial in Tyrrell's, holding that Montana courts could exercise general personal jurisdiction over BNSF.
- BNSF filed a petition for a writ of certiorari, which the U.S. Supreme Court granted.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Due Process Clause of the Fourteenth Amendment permit a state court to exercise general personal jurisdiction over an out-of-state corporation for claims unrelated to its in-state activities, where the corporation is not incorporated or headquartered in the state but conducts substantial business there?
Opinions:
Majority - Justice Ginsburg
No. The Due Process Clause does not permit a state court to exercise general personal jurisdiction over an out-of-state corporation for claims unrelated to its in-state activities unless the corporation is 'essentially at home' in the forum state. First, the Court held that the Federal Employers’ Liability Act (FELA), §56, does not confer personal jurisdiction. The statute's reference to where an action 'may be brought' is a venue provision for federal courts, and its 'concurrent jurisdiction' clause refers to subject-matter, not personal, jurisdiction. Second, applying the constitutional standard from Daimler AG v. Bauman, the Court found that general personal jurisdiction is only proper where a corporation's affiliations are so 'continuous and systematic' as to render it 'essentially at home.' The paradigm 'at home' forums are the state of incorporation and the principal place of business. While BNSF conducts substantial business in Montana, these activities are not so substantial in the context of its entire nationwide operations as to make this an 'exceptional case' where it would be considered 'at home' in Montana. Therefore, Montana courts lack general personal jurisdiction over BNSF for these claims.
Dissenting in part - Justice Sotomayor
No, the Court should not have decided the constitutional question but should have remanded the case for further analysis by the state court. While concurring that FELA §56 does not grant personal jurisdiction, the dissent argues that the majority incorrectly applied the Due Process standard. The dissent criticizes the restrictive 'at home' test from Daimler as a departure from the more holistic contacts analysis of International Shoe, arguing it creates inequities by shielding large, multistate corporations from jurisdiction. The dissent contends that the majority's comparative contacts analysis—weighing a defendant's in-state contacts against its nationwide operations—is improper. Rather than deciding the issue, the Court should have remanded to the Montana Supreme Court to determine if this was an 'exceptional case' warranting jurisdiction under the correct legal framework.
Analysis:
This case solidifies the restrictive 'at home' standard for general personal jurisdiction established in Goodyear and Daimler, confirming its application to all types of claims and defendants, including FELA claims against railroads. The decision makes it significantly more difficult for plaintiffs to sue large, multi-state corporations in forums other than their states of incorporation or principal places of business for claims that do not arise from the corporation's activities within that forum. By definitively interpreting FELA §56 as a venue provision, the Court also resolved a key statutory question, closing a potential avenue for plaintiffs to establish jurisdiction over railroads based solely on their 'doing business' in a state.
Unlock the full brief for BNSF Railway Co. v. Tyrell