BNSF Ry. v. Tyrrell
Supreme Court of the United States
April 25, 2017, Argued; May 30, 2017, Decided
Justice Ginsburg delivered the opinion of the Court.
The two cases we decide today arise under the Federal Employers’ Liability Act (FELA), 35 Stat. 65, as amended, 45 U. S. C. §51 et seq., which makes railroads liable in money damages to their employees for on-the-job injuries. Both suits were pursued in Montana state courts although the injured workers did not reside in Montana, nor were they injured there. The defendant railroad, BNSF Railway Company (BNSF), although “doing business” in Montana when the litigation commenced, was not incorporated in Montana, nor did it maintain its principal place of business in that State. To justify the exercise of personal jurisdiction over BNSF, the Montana Supreme Court relied on §56, which provides in relevant part:
“Under this chapter an action may be brought in a district court of the United States, in the district of the residence of the defendant, or in which the cause of action arose, or in which the defendant shall be doing business at the time of commencing such action. The jurisdiction of the courts of the United States under this chapter shall be concurrent with that of the courts of the several [***6] States.”
We hold that §56 does not address [**42] personal jurisdiction over railroads. Its first relevant sentence is a venue prescription governing proper locations for FELA suits filed in federal court. The provision’s second relevant sentence, using the term “concurrent” jurisdiction, refers to subject-matter jurisdiction, not personal jurisdiction. It simply clarifies that the federal courts do not have exclusive subject-matter jurisdiction over FELA suits; state courts can hear them, too.
[*1554] Montana’s Supreme Court, in the alternative, relied on state law, under which personal jurisdiction could be asserted over “persons found within . . . Montana.” Mont. Rule Civ. Proc. 4(b)(1) (2015). BNSF fit that bill, the court stated, because it has over 2,000 miles of railroad track and employs more than 2,000 workers in Montana. Our precedent, however, explains that the Fourteenth Amendment’s Due Process Clause does not permit a State to hale an out-of-state corporation before its courts when the corporation is not “at home” in the State and the episode-in-suit occurred elsewhere. Daimler AG v. Bauman, 571 U. S. ___, ___, 134 S. Ct. 746, 187 L. Ed. 2d 624, 633 (2014) (internal quotation marks omitted). We therefore reverse the judgment of the Montana Supreme Court.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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137 S. Ct. 1549 *; 198 L. Ed. 2d 36 **; 2017 U.S. LEXIS 3395 ***; 85 U.S.L.W. 4286; 41 I.E.R. Cas. (BNA) 1809; 26 Fla. L. Weekly Fed. S 612; 2017 WL 2322834
BNSF RAILWAY CO., Petitioner v. KELLI TYRRELL, special administrator for the ESTATE OF BRENT T. TYRRELL, DECEASED, et al.
Notice: The LEXIS pagination of this document is subject to change pending release of the final published version.
Prior History: [***1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF MONTANA
Tyrrell v. BNSF Ry. Co., 2016 MT 126, 383 Mont. 417, 373 P.3d 1, 2016 Mont. LEXIS 368 (May 31, 2016)
Disposition: Reversed and remanded.
personal jurisdiction, railroad, state court, venue, courts, cases, contacts, general jurisdiction, sentence, exercise of personal jurisdiction, concurrent, do business, principal place of business, federal court, suits, subject-matter, marks, first sentence, authorize, quotation, forum state, systematic, track
Governments, Federal Government, Employees & Officials, Workers' Compensation & SSDI, Remedies Under Other Laws, Federal Employers' Liability Act, Civil Procedure, In Rem & Personal Jurisdiction, In Personam Actions, Due Process, Constitutional Law, Fundamental Rights, Procedural Due Process, Scope of Protection, Preliminary Considerations, Venue, General Overview, Legislation, Interpretation, Pleadings, Service of Process, Long Arm Jurisdiction, Substantial Contacts