Burlington Northern Railroad v. Ford
119 L. Ed. 2d 432, 1992 U.S. LEXIS 3541, 504 U.S. 648 (1992)
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Rule of Law:
A state venue statute that differentiates between domestic and foreign corporations does not violate the Equal Protection Clause of the Fourteenth Amendment, provided the distinction rationally furthers a legitimate state interest, such as balancing the convenience of the parties and promoting judicial efficiency.
Facts:
- Burlington Northern Railroad Company is incorporated in Delaware and has its principal place of business in Fort Worth, Texas.
- Burlington Northern operates railroad lines and maintains a place of business in Montana, including in Hill County.
- William D. Ford and Thomas L. Johnson were employees of Burlington Northern.
- Ford and Johnson alleged they sustained injuries while working at Burlington's premises in Sheridan, Wyoming.
Procedural Posture:
- William Ford and Thomas Johnson filed separate FELA claims against Burlington Northern Railroad Company in the Montana state trial court for Yellowstone County.
- In each case, Burlington Northern filed a motion to change venue to Hill County, its asserted principal place of business in Montana.
- The trial court denied both motions.
- Burlington Northern, the appellant, brought interlocutory appeals from the trial court's denials.
- The Supreme Court of Montana consolidated the appeals and affirmed the trial court's decisions, holding that the venue statute did not violate the Equal Protection Clause.
- The United States Supreme Court granted certiorari to review the decision of the Supreme Court of Montana.
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Issue:
Does a Montana venue statute that permits a foreign corporation to be sued in any county within the state, while restricting suits against a domestic corporation to the county of its principal place of business, violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Souter
No, the Montana venue statute does not violate the Equal Protection Clause. Because the statute does not affect a fundamental right or employ a suspect classification, it is subject only to rational-basis review. The state has a legitimate interest in determining the appropriate location for trials by balancing the disparate interests of plaintiffs and defendants. Montana could rationally conclude that for a foreign corporation, the inconvenience of defending a suit is significant regardless of which county within the state is chosen, thus justifying a plaintiff's choice of any county. Conversely, the state could reasonably decide that subjecting a domestic corporation to suit far from its principal place of business within the state would create a significant tactical disadvantage, thereby justifying a single-county rule for them. Using the state of incorporation as a proxy for a corporation's 'residence' or principal place of business is a rational, though imprecise, choice that promotes administrative convenience and avoids extensive litigation over venue, which are legitimate state ends.
Analysis:
This decision reaffirms the broad latitude states have under rational-basis review to create procedural rules, such as those governing venue. It solidifies the principle that administrative convenience and the desire to avoid 'wasteful sideshows of venue litigation' are legitimate state interests that can justify classifications that are not perfectly tailored. The Court's reasoning narrows the applicability of its earlier precedent in Power Manufacturing Co. v. Saunders, suggesting that such venue statutes will be upheld so long as the state can articulate any plausible, rational basis for distinguishing between foreign and domestic corporations.
