McKnett v. St. Louis & San Francisco Railway Co.

Background

McKnett, a Tennessee resident, sued a railroad company that was a foreign corporation doing business in Alabama for injuries suffered in Tennessee under the Federal Employers’ Liability Act. The Alabama trial court dismissed the case for lack of jurisdiction, and the Alabama courts affirmed, relying on a state statute and past rules that limited suits against foreign corporations to causes arising under the law of another state.

Reasoning

The central question was whether an Alabama court of ordinary jurisdiction could refuse to hear a suit simply because the right being enforced comes from a federal law and the injury happened in another State. The Supreme Court explained that state courts of general jurisdiction, when otherwise appropriate under state law, cannot deny access on the ground that the claim enforces a federal statute. The opinion relied on constitutional protections that forbid states from discriminating against rights created by federal law and cited prior decisions holding state courts may not refuse federal causes when their ordinary jurisdiction fits the dispute. Because the denial was based solely on the source of the law, the Court reversed.

Real world impact

As a practical result, injured workers can bring federal employer-liability claims in state courts that ordinarily have jurisdiction, even if the injury occurred in another State. States may still set ordinary jurisdictional rules, but they cannot exclude claims solely because they rest on federal law. This decision removes a barrier that had prevented some plaintiffs from using state courts to enforce federal workplace-injury rights.