BNSF R. Co. v. Tyrrell
The Supreme Court ruled that Montana courts could not hear injury lawsuits against a railroad that merely does business in the state, when neither injured worker was hurt there or lived there. The railroad statute the workers relied on only governs where federal lawsuits may be filed, not which courts have power over the defendant.
The decision confirms that the same due-process limits on suing out-of-state companies apply no matter what kind of claim is involved, closing off a route plaintiffs had used to sue railroads in whatever state had significant track mileage or employees, regardless of any connection to the actual injury.
“the general jurisdiction inquiry does not focus solely on the magnitude of the defendant’s in-state contacts”
Explaining why BNSF's sizable Montana operations still weren't enough to make it 'at home' there.
How it got here: BNSF's motion to dismiss for lack of jurisdiction was granted in one case and denied in the other; the Montana Supreme Court consolidated and upheld jurisdiction, prompting BNSF's appeal.
The Case in Depth
What happened
Robert Nelson, a North Dakota resident, and Kelli Tyrrell, representing her late husband's estate, each sued BNSF Railway in Montana state court under a federal law that lets railroad workers recover damages for on-the-job injuries. Neither worker was injured in Montana or lived there. BNSF is incorporated in Delaware and headquartered in Texas, though it operates some track and employs some workers in Montana.
The question before the Court
Could two railroad workers who weren't injured in Montana, and don't live there, sue the railroad in Montana courts anyway?
The Court's answer
No — the Supreme Court ruled that Montana courts could not hear these lawsuits. The federal railroad-injury statute the workers relied on doesn't give courts power over the defendant at all; it only addresses where federal suits may be filed and confirms that both state and federal courts can hear this type of claim. That left the case to be decided under ordinary constitutional due-process rules.
Under those rules, a company can be sued anywhere for claims unrelated to that state only if it is essentially 'at home' there — usually where it's incorporated or headquartered. Because BNSF's Montana track and workforce were a small slice of its nationwide operations, and neither worker's injury had anything to do with Montana, the Court held Montana courts lacked jurisdiction.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Workers injured on the job by railroads (or other large multistate companies) generally cannot pick any state where the company does substantial business to file suit — they must sue where the company is incorporated, headquartered, or where the injury happened. This narrows plaintiffs' choice of favorable courts and forces national companies to defend suits mainly in their home states.
What changes now
The case goes back to the Montana courts, but under the Supreme Court's ruling those courts lack the power to hear these particular claims since they have no connection to Montana. The decision is a final ruling on the legal standard, though it leaves unresolved an argument the workers raised — that BNSF had separately consented to jurisdiction in Montana — which the lower courts never addressed.
What this does not decide
The Court did not decide whether BNSF had separately consented to being sued in Montana, since the Montana Supreme Court never addressed that argument. The ruling also does not disturb a railroad's exposure to suit in states where the injury actually happened or where the company is truly at home.
Concurrences and dissents
Dissent in part — Justice Sotomayor
“It is individual plaintiffs, harmed by the actions of a farflung foreign corporation, who will bear the brunt of the majority’s approach”Warning that the ruling makes it harder for injured workers to sue large multistate companies.
Justice Sotomayor agreed that the federal railroad statute does not confer personal jurisdiction and that a railroad claim isn't automatically treated differently for jurisdiction purposes. But she continued to object to the 'at home' test from an earlier case, arguing it unfairly shields large multistate and foreign corporations from suit almost anywhere except their headquarters or incorporation state. She also thought the Court should have sent the case back to the Montana courts to apply the correct standard themselves, rather than deciding the outcome itself.
How the Court got there
The legal reasoning, step by step
- The Court first read the text of the federal railroad-injury statute's venue-like sentence, which says such suits 'may be brought' in certain federal districts, and concluded — consistent with earlier rulings — that this sentence sets only venue (which courthouse is convenient) for federal suits, not which courts have power over the defendant (personal jurisdiction).
- The Court then read the statute's next sentence, which says federal and state courts have 'concurrent' jurisdiction, and explained that 'concurrent jurisdiction' here is a term of art referring to subject-matter jurisdiction — meaning state courts are also allowed to hear these claims — not personal jurisdiction over any particular defendant.
- Having found the federal statute silent on personal jurisdiction, the Court turned to the Fourteenth Amendment's Due Process Clause, which limits when a state can force an out-of-state company into its courts. Under existing precedent, a state may exercise all-purpose ('general') jurisdiction over a company only if the company is essentially 'at home' there — typically its place of incorporation or main headquarters.
- The Court explained that a company's operations elsewhere can, in rare 'exceptional' cases, be so substantial that the company is at home there too, but that this due-process rule applies equally regardless of the type of claim or kind of business involved — rejecting the lower court's view that railroad cases are different.
- Applying that at-home standard to the facts, the Court found that BNSF's track mileage and employees in Montana were a small share of its nationwide operations, so BNSF was not at home in Montana, and Montana courts therefore lacked general jurisdiction over claims unrelated to anything that happened there.
Doctrinal impact
Cases affected by this decision
Reaffirms Daimler AG v. Bauman (571 U. S. ___)
The Court relies on Daimler's 'at home' test as the controlling standard for general jurisdiction over corporations.
Distinguishes International Shoe Co. v. Washington (326 U. S. 310)
The Court says International Shoe involved claims tied to the defendant's in-state activity, unlike this case.