Law School Case Brief
BNSF Ry. v. Tyrrell - 137 S. Ct. 1549 (2017)
Case law clarifies that a court may assert general jurisdiction over foreign (sister-state or foreign-country) corporations to hear any and all claims against them when their affiliations with the State are so continuous and systematic as to render them essentially at home in the forum State. The paradigm forums in which a corporate defendant is at home are the corporation’s place of incorporation and its principal place of business. The exercise of general jurisdiction is not limited to these forums; in an exceptional case, a corporate defendant’s operations in another forum may be so substantial and of such a nature as to render the corporation at home in that State.
The Federal Employers' Liability Act (FELA), made railroads liable in money damages to their employees for on-the-job injuries. Robert Nelson, a North Dakota resident, brought a FELA suit against the BNSF Railway Company (BNSF) in a Montana state court, alleging that he had sustained injuries while working for BNSF. 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 maintains less than 5% of its work force and about 6% of its total track mileage in the State. Contending that it was not “at home” in Montana, as required for the exercise of general personal jurisdiction, 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 and was “found within” the State within Montana law.
Did the Montana Court have jurisdiction?
The Court held that the Federal Employers' Liability Act provision, which concerned Federal District Court venue in cases involving railroads, did not address personal jurisdiction over railroads. The Court held that the state supreme court ran afoul of the Fourteenth Amendment when it exercised personal jurisdiction over a railroad pursuant to Mont. R. Civ. P. 4(b)(1) (2015) where the railroad was neither incorporated nor maintained its principal place of there, and its in-state business, which included railroad tracks and employees, did not suffice to permit the assertion of general jurisdiction over the employees' on-the-job injury claims that were unrelated to any activity occurring in the state.
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