Canadian Northern Railway Co. v. Eggen

Background

A South Dakota man went to Canada to work for a Canadian railroad and was badly injured in Saskatchewan. He returned to South Dakota and sued the Canadian company in a federal court sitting in Minnesota almost two years after the accident. Canadian law required this kind of suit within one year. Minnesota had a long-standing law saying if a claim is already barred where it arose, a nonresident cannot sue in Minnesota unless the person is a Minnesota citizen who has owned the claim since it arose. The federal appeals court struck down Minnesota’s law as violating the Constitution’s promise that citizens of each State have the same basic privileges and protections elsewhere.

Reasoning

The Court considered whether the Minnesota law denied a fundamental privilege of citizens of other States. It acknowledged that citizens have a right to use another State’s courts, but said that right is limited to 'fundamental' privileges. Minnesota’s law gave nonresidents one year to sue, a period the State considered reasonably adequate to protect claims before witnesses scattered or memories faded. The law had been on the books since statehood and was similar to statutes in other States. The Court rejected the idea that nonresidents must have precisely identical procedural rights as residents. Finding Minnesota’s one-year rule reasonable and adequate, the Court upheld the statute and reversed the appeals court.

Real world impact

States may set reasonable conditions and short timeframes for nonresidents to bring suits. People injured away from home should act promptly, because a foreign time limit can block later lawsuits in other States.