BNSF Ry. Co. v. Tyrrell
The Court ruled that Montana courts could not hear injury lawsuits against BNSF Railway brought by workers who were neither Montana residents nor injured there, because a federal railroad-injury law does not grant states that kind of authority and the railroad isn't legally 'at home' in Montana.
The decision reinforces strict limits on when a company can be sued in a state with which it has only a partial business presence, protecting large multistate companies from being sued anywhere they merely do business.
“Our precedent, however, explains that the Fourteenth Amendment's Due Process Clause does not permit a State to hale an out-of-state corporation before its courts when the corporation is not "at home" in the State and the episode-in-suit occurred elsewhere.”
States the core due-process limit on suing out-of-state companies.
How it got here: BNSF sought dismissal for lack of personal jurisdiction in both suits; the Montana Supreme Court allowed jurisdiction, and BNSF asked the Supreme Court to review.
The Case in Depth
What happened
Robert Nelson, a North Dakota resident, and Kelli Tyrrell, representing her late husband's estate, separately sued BNSF Railway in Montana state court under a federal law that lets railroad workers sue for on-the-job injuries. Neither worker was injured in Montana or worked there; BNSF is incorporated in Delaware and headquartered in Texas but runs trains and employs thousands of people in Montana.
The question before the Court
Could two railroad workers who were never injured in Montana and don't live there sue the railroad in Montana courts anyway?
Why it matters
Workers hurt on the job while working for a nationwide company generally must sue where the company is incorporated, headquartered, or where the injury actually happened — not just anywhere the company operates trains or stores. This narrows the menu of courthouses available to injured workers and out-of-state plaintiffs generally, funneling more suits toward a defendant's home state.
What changes now
The cases return to the Montana courts, but not to proceed there — since the Court held Montana lacks personal jurisdiction, the underlying suits cannot go forward in Montana and the workers would need to refile where BNSF is 'at home' or where their injuries occurred. The ruling is a final merits decision, not temporary, and applies going forward to similar suits against multistate corporate defendants.
What this does not decide
The Court did not decide whether BNSF might have consented to jurisdiction in Montana by another route, since the Montana Supreme Court hadn't addressed that argument. It also did not decide whether Montana could exercise case-specific jurisdiction over BNSF for injuries actually connected to its Montana operations.
Concurrences and dissents
Dissent in part — Justice Sotomayor
“The majority's approach grants a jurisdictional windfall to large multistate or multinational corporations that operate across many jurisdictions.”Sotomayor's central objection to the majority's reliance on the 'at home' test.
Justice Sotomayor agreed that the federal railroad law doesn't grant personal jurisdiction and that a railroad's special status doesn't decide the due-process question, but she objected to the majority reaffirming Daimler's strict 'at home' test, which she argues creates a jurisdictional windfall for large multistate corporations. She also would have remanded to let the Montana Supreme Court apply the correct standard itself rather than have the Court decide the fact-intensive question in the first instance.
How the Court got there
The legal reasoning, step by step
- The Court first read the federal railroad-injury law's venue sentence, which lists where suit 'may be brought' in federal court, as addressing only venue — the proper location for a federal lawsuit — not personal jurisdiction, the court's power over the defendant itself.
- The Court read the law's second relevant sentence, which mentions 'concurrent' jurisdiction of state and federal courts, as addressing subject-matter jurisdiction (which kinds of cases a court can hear at all), not personal jurisdiction over a particular company.
- Because the federal statute said nothing about personal jurisdiction, the Court turned to Montana's own jurisdiction rule and then asked whether exercising that jurisdiction would satisfy the Fourteenth Amendment's Due Process Clause.
- Applying the framework from Daimler AG v. Bauman, the Court explained that a corporation can be sued on any claim, regardless of where it arose, only in places where it is 'essentially at home' — typically its state of incorporation and principal place of business, unless the case is the rare 'exceptional case.'
- The Court found that BNSF's sizable but still partial presence in Montana — a fraction of its total track, workforce, and revenue — did not make it 'at home' there, because the inquiry looks at the company's activities as a whole, not just the raw size of its in-state footprint.
- Because neither worker's injury had any connection to Montana, and BNSF was not 'at home' there, the Court concluded that exercising this kind of all-purpose jurisdiction over BNSF in Montana violated due process.
Doctrinal impact
Cases affected by this decision
Reaffirms Daimler AG v. Bauman (134 S. Ct. 746)
The Court leans on Daimler's rule that companies can only be sued anywhere for unrelated claims where they are 'at home.'
Distinguishes International Shoe Co. v. Washington (326 U.S. 310)
The Court says this case differs because the claims there arose from in-state activity, unlike Nelson's and Tyrrell's claims.