Burlington Northern Railroad v. Ford

Background

Two railroad workers sued a railroad company incorporated in Delaware with its main office in Fort Worth, Texas. They filed federal employer-injury claims after accidents in Wyoming and brought those suits in Yellowstone County, Montana. Montana law says a plaintiff may sue a corporation incorporated in Montana only in the county where that corporation has its principal place of business, but may sue a corporation incorporated elsewhere in any Montana county. The railroad asked to move the cases to a different county; state courts denied the requests, and the cases reached the Supreme Court.

Reasoning

The main question was whether that difference in who can be sued where violated equal treatment under the Fourteenth Amendment. The Court applied a deferential test because the rule did not burden a fundamental right or a protected group. It found Montana had reasonable grounds: the State could favor litigating near a corporation’s home office, use state of incorporation as a practical proxy for domicile, and avoid expensive disputes over determining a company’s principal place of business. The Court distinguished an older Arkansas case that struck down a similar rule because Arkansas’ law was less tailored. On that record, Montana’s choice was rational and constitutional.

Real world impact

As a practical matter, corporations incorporated outside Montana but with offices in the State remain subject to suit in any county a plaintiff chooses, while Montana-incorporated companies generally can be sued only in their home county. The ruling upholds Montana’s policy tradeoffs and leaves room for different choices by other States or different findings on a fuller record.