BNSF Ry. Co. v. Tyrrell

Background

Two injured workers sued BNSF Railway in Montana state courts under the Federal Employers’ Liability Act (FELA). Neither worker lived in Montana or was hurt there. BNSF is incorporated in Delaware and headquartered in Texas but runs about 2,061 miles of track and employs roughly 2,100 people in Montana. The Montana Supreme Court said a federal venue statute (§56) and a state rule allowing suits against “persons found” in Montana allowed the courts to hear the cases.

Reasoning

The Court asked whether §56 lets state courts exercise personal jurisdiction over railroads and whether Montana’s assertion of jurisdiction complied with the Constitution’s due process protections. The Court held §56 is a federal venue rule and that its reference to “concurrent” jurisdiction means state and federal courts share subject-matter authority — it does not grant power to make a company appear in a state court. Applying the Court’s due process framework, the Justices concluded BNSF was not “at home” in Montana and that its Montana business did not justify general jurisdiction over claims unrelated to Montana.

Real world impact

The Court reversed the Montana Supreme Court and sent the cases back for further proceedings consistent with this opinion. The decision means state courts cannot rely on §56 to haul railroads into court when the claim has no connection to the forum state. It leaves open other bases for jurisdiction — for example, consent — which this Court did not decide.

Dissents or concurrances

Justice Sotomayor agreed that §56 does not authorize state personal jurisdiction but dissented from the judgment, criticizing the Court’s narrow reading of when a corporation can be “at home” and urging more factfinding by the state court.