BNSF R. Co. v. Tyrrell
Headline: Court limits states’ power to sue big companies where they do some business, blocks Montana from treating BNSF as subject to all-claims lawsuits for injuries that occurred elsewhere.
Holding: The Court held that the federal FELA provision does not grant state courts personal jurisdiction over railroads and that Montana’s exercise of general jurisdiction over BNSF violated the Due Process Clause because BNSF is not “at home” there.
- Prevents suing a railroad in Montana for injuries that occurred elsewhere.
- Says FELA’s statute governs where cases are filed, not states’ power to exercise personal jurisdiction.
- Narrows where multistate companies can be sued on unrelated claims.
Summary
Background
Two separate railroad workers sued BNSF under the Federal Employers’ Liability Act in Montana state courts. One plaintiff is a North Dakota resident who alleged knee injuries; the other is the administrator of a deceased worker’s estate alleging fatal exposure-related cancer. Neither worker was injured in Montana. BNSF is incorporated in Delaware, has its main place of business in Texas, operates about 2,061 miles of track in Montana (about 6% of its total), employs roughly 2,100 Montanans (under 5% of its workforce), and generates less than 10% of its revenue there.
Reasoning
The Montana Supreme Court said Montana could assert general jurisdiction because BNSF was “doing business” under 45 U.S.C. §56 and was “found within” Montana under state rule. The U.S. Supreme Court rejected that reading, holding that §56 deals with venue and concurrent subject-matter jurisdiction, not personal jurisdiction. The Court applied its Daimler decision: a state may exercise general jurisdiction only where a corporation is essentially “at home,” normally at its place of incorporation or principal place of business, and BNSF’s Montana activity did not meet that standard. The Court therefore found Montana’s assertion of general jurisdiction inconsistent with the Fourteenth Amendment.
Real world impact
The ruling limits where people can sue large, multistate corporations for claims unrelated to the forum. FELA plaintiffs with injuries that occurred elsewhere cannot force suits in Montana merely because the railroad does business there. The decision sends disputes over venue and state court authority back to lower courts to sort out under the Court’s “at home” test.
Dissents or concurrances
Justice Sotomayor joined parts of the Court’s opinion but disagreed with the Court’s strict reading of Daimler, arguing for a more flexible, fact-based approach and seeking remand for further factfinding.
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