Mallory v. Norfolk Southern R. Co
Headline: Ruling lets Pennsylvania courts hear lawsuits against companies that registered to do business there, upholding a long‑standing registration‑based rule and making it easier for plaintiffs to sue out‑of‑state firms in Pennsylvania.
Holding:
- Allows Pennsylvania courts to hear suits against companies that registered to do business there.
- Companies may face litigation in Pennsylvania for claims arising elsewhere.
- Leaves open other challenges on remand, such as Commerce Clause arguments.
Summary
Background
Robert Mallory, a former freight‑car mechanic, sued his long‑time employer, Norfolk Southern, in Pennsylvania state court under the Federal Employers' Liability Act after a cancer diagnosis he attributes to workplace exposures in Ohio and Virginia. Mallory filed the complaint in Pennsylvania even though he and the alleged exposures were linked to Virginia and Ohio; Norfolk Southern is incorporated and headquartered in Virginia but registered to do business in Pennsylvania and has substantial operations there.
Reasoning
The central question was whether Pennsylvania may require an out‑of‑state corporation to consent to suit as a condition of registering to do business without violating the Due Process Clause. The Court held that this case is controlled by Pennsylvania Fire Ins. Co. v. Gold Issue Mining & Milling Co., a long‑standing decision that allows a State to require such registration and agency for service. Because Norfolk Southern registered in Pennsylvania, named an in‑state office, and accepted the benefits and burdens of doing business there, the Court concluded Pennsylvania courts may exercise general jurisdiction and that the Pennsylvania Supreme Court erred in refusing to follow controlling precedent. The judgment was vacated and the case remanded.
Real world impact
As a result, plaintiffs can bring claims in Pennsylvania courts against companies that have registered to do business there, even when the plaintiff and the underlying injury or conduct occurred elsewhere. Companies that register in Pennsylvania face the real risk of defending out‑of‑state claims in Pennsylvania. The Court's ruling is on jurisdiction; other constitutional challenges, including the state's Commerce Clause argument, were not decided and may be raised on remand.
Dissents or concurrances
A majority of Justices agreed with the judgment; Justice Jackson and Justice Alito filed separate concurrences. Justice Barrett dissented, joined by Chief Justice Roberts and Justices Kagan and Kavanaugh.
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