BNSF Ry. Co. v. Tyrrell
41 I.E.R. Cas. (BNA) 1809, 198 L. Ed. 2d 36, 137 S. Ct. 1549 (2017)
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Rule of Law:
The Fourteenth Amendment's Due Process Clause requires that a state court may only exercise general personal jurisdiction over a corporate defendant if the corporation's affiliations with the state are so continuous and systematic as to render it essentially 'at home' there. Merely doing substantial business in a state is insufficient to establish general personal jurisdiction for claims that do not arise from the corporation's in-state activities.
Facts:
- BNSF Railway Company (BNSF) is incorporated in Delaware and has its principal place of business in Texas.
- BNSF operates over 2,000 miles of railroad track and employs over 2,000 workers in Montana, but this constitutes less than 10% of its total track mileage, workforce, and revenue.
- Robert Nelson, a North Dakota resident and BNSF employee, allegedly sustained knee injuries while working for BNSF outside of Montana.
- Brent Tyrrell, a BNSF employee, allegedly developed fatal kidney cancer from exposure to carcinogenic chemicals during his work for BNSF, none of which occurred in Montana.
- Neither Nelson's injury nor Tyrrell's exposure to chemicals arose from or were related to any work performed in Montana.
- Robert Nelson and Kelli Tyrrell (on behalf of Brent Tyrrell's estate) were not residents of Montana.
Procedural Posture:
- Robert Nelson sued BNSF in a Montana state trial court under FELA.
- Kelli Tyrrell, as administrator of her husband's estate, sued BNSF in a Montana state trial court under FELA.
- BNSF filed motions to dismiss both cases for lack of personal jurisdiction.
- The trial court granted the motion to dismiss in Nelson's case but denied the motion in Tyrrell's case.
- The cases were consolidated on appeal to the Montana Supreme Court.
- The Montana Supreme Court held that Montana courts could exercise general personal jurisdiction over BNSF and reversed the dismissal in Nelson's case.
- BNSF successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Due Process Clause of the Fourteenth Amendment permit a state court to exercise general personal jurisdiction over a railroad corporation that conducts substantial business within the state, but is not incorporated or headquartered there, for claims unrelated to its in-state activities?
Opinions:
Majority - Justice Ginsburg
No. The Due Process Clause does not permit a state to exercise general personal jurisdiction over a corporation that is not 'at home' in the state for claims that arose elsewhere. First, the Court determined that the Federal Employers' Liability Act (FELA), 45 U.S.C. § 56, is a venue statute for federal courts and a concurrent subject-matter jurisdiction provision for state courts; it does not grant personal jurisdiction. Second, applying the standard from 'Daimler AG v. Bauman', the Court found that general personal jurisdiction is limited to forums where a corporation is 'essentially at home.' The paradigm forums for being 'at home' are the state of incorporation and the principal place of business. Although BNSF conducts substantial business in Montana, its in-state activities are not so continuous and systematic in the context of its nationwide operations as to render it 'at home' in Montana. Therefore, Montana courts lack general personal jurisdiction over BNSF for claims unrelated to its activities within the state.
Concurring-in-part-and-dissenting-in-part - Justice Sotomayor
No, but for different reasons regarding the constitutional analysis. Justice Sotomayor concurred that FELA § 56 does not confer personal jurisdiction. However, she dissented from the Court's application of the 'Daimler' 'at home' test, arguing it is an overly restrictive departure from the 'International Shoe' standard of 'continuous and systematic' contacts. She argued this test provides a 'jurisdictional windfall' to large, multistate corporations, making it difficult for individuals to hold them accountable. Sotomayor criticized the majority's comparative contacts analysis and argued that the Court should have remanded the case to the Montana Supreme Court to determine if BNSF's contacts made this an 'exceptional case' justifying general jurisdiction, rather than deciding the factual question itself.
Analysis:
This decision reinforces and solidifies the Supreme Court's restrictive approach to general personal jurisdiction established in 'Goodyear' and 'Daimler'. It clarifies that the 'at home' standard is a universal due process requirement that does not change based on the defendant's industry (e.g., railroads) or the nature of the underlying federal claim (e.g., FELA). The ruling significantly curtails the ability of plaintiffs to 'forum shop' by suing large corporations in any state where they have substantial business operations for claims that arose elsewhere. Consequently, it channels such litigation to the defendant's state of incorporation or principal place of business, potentially increasing burdens on plaintiffs while providing greater predictability for corporate defendants.
