Douglas v. New York, New Haven & Hartford Railroad

Background

A Connecticut resident was injured in Connecticut and sued a Connecticut corporation in New York, where that company was doing business. The New York trial court dismissed the case under a state law that gives courts discretion in these foreign-corporation suits. New York’s intermediate and highest state courts affirmed the dismissal. The plaintiff argued the statute unlawfully discriminated against citizens of other States under the Constitution’s Privileges and Immunities protection and added that the federal Employers’ Liability Act required state courts to accept such suits.

Reasoning

The Court said the New York law can reasonably be read to mean “resident” as someone actually living in the State, not merely a person who happens to be a citizen of New York. That construction, supported by New York decisions, avoids treating in-state and out-of-state citizens differently as citizens. The Court emphasized that a distinction based on residence can be justified and endorsed prior decisions that separate residency from citizenship. The Court also held the federal Employers’ Liability statute merely authorized state courts to hear these cases; it did not force state courts to accept them against valid state rules or excuses.

Real world impact

As a result, out-of-state plaintiffs who do not actually live in New York may be denied access to sue foreign corporations there; New York courts may favor local residents when courts are crowded. The ruling affirms that the federal Employers’ Liability law does not compel state courts to hear such suits.

Dissents or concurrances

Three Justices—the Chief Justice, Justice Van Devanter, and Justice Butler—recorded a dissent from the Court’s judgment.