Law School Case Brief
BNSF Ry. Co. v. Tyrrell - 137 S. Ct. 1549 (2017)
A court violates the 14th Amendment when it exercises personal jurisdiction over a railroad where the railroad is neither incorporated nor maintains its principal place of there and its in-state business, which includes railroad tracks and employees, does not suffice to permit the assertion of general jurisdiction over the employees' on-the-job injury claims that are unrelated to any activity occurring in the state.
Respondent Robert Nelson, a North Dakota resident, brought a Federal Employers’ Liability Act (FELA) suit against petitioner BNSF Railway Company (BNSF) in a Montana state court, alleging that he had sustained injuries while working for BNSF. FELA made railroads liable in money damages to their employees for on-the-job injuries. Respondent Kelli Tyrrell, appointed in South Dakota as the administrator of her husband Brent Tyrrell's estate, also sued BNSF under FELA in a Montana state court, alleging that Brent had developed a fatal cancer from his exposure to carcinogenic chemicals while working for BNSF. Neither worker was injured in Montana. Neither incorporated nor headquartered there, BNSF maintained less than five percent of its work force and about six percent of its total track mileage in the State. Contending that it is not “at home” in Montana, as required for the exercise of general personal jurisdiction under Daimler AG v. Bauman, BNSF moved to dismiss both suits. Its motion was granted in Nelson's case and denied in Tyrrell's.
After consolidating the two cases, the Montana Supreme Court held that Montana courts could exercise general personal jurisdiction over BNSF because the railroad both “did business” in the State within the meaning of 45 U.S.C. §56 and was “found within” the State within the compass of Mont. R. Civ. Proc. 4(b)(1). The Montana Supreme Court also held that the due process limits articulated in Daimler did not control because Daimler did not involve a FELA claim or a railroad defendant. Petitioner BNSF sought review.
Does the Federal Employers’ Liability Act authorize state courts to exercise personal jurisdiction over a railroad solely on the ground that the railroad does some business in their state?
The Supreme Court of the United States granted certiorari to resolve whether § 56 of FELA, which concerned Federal District Court venue in cases involving railroads, authorizes state courts to exercise personal jurisdiction over railroads doing business in their States but not incorporated or headquartered there, and whether the Montana courts’ exercise of personal jurisdiction in these cases comports with due process. The Court held that the relevant language in FELA addresses venue and subject-matter jurisdiction, not personal jurisdiction. The statute lacked the language that Congress typically uses to provide for personal jurisdiction, and there was no indication in the legislative history that Congress intended to otherwise. Therefore, the exercise of personal jurisdiction in this case must meet the requirements of the Due Process Clause of the 14th Amendment. Because neither plaintiff was injured in Montana or during work related to Montana, the exercise of personal jurisdiction here would violate due process, so only the exercise of general jurisdiction would be permissible. Under Daimler AG v. Baumann, BNSF did not have sufficient contacts with Montana to be “at home” in Montana for the purpose of general jurisdiction. Therefore, the judgment of the Montana Supreme Court was reversed, and the cases were remanded
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