BNSF R. Co. v. Tyrrell, 137 S. Ct. 1549

Background

Two FELA suits were filed in Montana state court by non‑Montana plaintiffs (Nelson and Tyrrell) for injuries not sustained in Montana against BNSF Railway (Delaware incorporation; principal place of business in Texas).
BNSF operates ~2,061 miles of track and employs ~2,100 workers in Montana (minority percentages of its nationwide operations).
Montana Supreme Court held Montana courts had general personal jurisdiction over BNSF based on 45 U.S.C. §56’s “doing business” language and Mont. R. Civ. P. 4(b)(1) (“persons found within” Montana).
BNSF argued it was not “at home” in Montana under Daimler AG v. Bauman and moved to dismiss for lack of personal jurisdiction; lower Montana rulings conflicted (one dismissal, one denial) before consolidation.
The U.S. Supreme Court granted certiorari to decide (1) whether §56 authorizes state‑court personal jurisdiction over railroads doing business in the state, and (2) whether Montana’s exercise of jurisdiction satisfied the Due Process Clause.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 45 U.S.C. §56 authorize personal jurisdiction in state courts over railroads “doing business” in the State?	§56’s venue language and the sentence about concurrent jurisdiction mean federal courts could exercise jurisdiction where the railroad is doing business and that grant extends to state courts.	§56 governs venue for federal courts and the “concurrent” language addresses subject‑matter jurisdiction; it does not create personal jurisdiction.	Held: §56 does not address personal jurisdiction. The first sentence is a federal‑venue provision; the second confirms concurrent subject‑matter jurisdiction.
Can Montana assert general personal jurisdiction under state law (Mont. R. Civ. P. 4(b)(1)) over BNSF given its in‑state activities?	Montana law and §56 support treating a railroad doing substantial business as subject to general jurisdiction in the State.	BNSF is not incorporated or headquartered in Montana; its in‑state activities are insufficient under federal Due Process limits (Daimler) to render it “at home.”	Held: Under the Fourteenth Amendment, BNSF is not “at home” in Montana; Montana’s assertion of general jurisdiction violates due process.
Does Daimler’s “at home” test apply to FELA claims or to railroads specifically?	Plaintiffs argued Daimler’s limits need not apply to FELA suits or to railroads.	Daimler’s due‑process constraint is claim‑ and industry‑neutral and applies here.	Held: Daimler applies broadly; the type of claim (FELA) or that the defendant is a railroad does not alter the due process analysis.
Did the Montana Supreme Court need to consider BNSF’s consent to jurisdiction?	Plaintiffs suggested consent might support jurisdiction.	BNSF disputed consent but Montana court didn’t address the point.	Held: SCOTUS did not decide consent because Montana Supreme Court did not rule on it; the issue is left unaddressed.

Key Cases Cited

Baltimore & Ohio R. Co. v. Kepner, 314 U.S. 44 (interpreting §56 clause as a federal‑venue provision)
Second Employers’ Liability Cases, 223 U.S. 1 (construing concurrent jurisdiction language as subject‑matter concurrency)
International Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts standard for personal jurisdiction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (limits on general jurisdiction)
Daimler AG v. Bauman, 571 U.S. _ (adopting "at home" standard for general jurisdiction)
Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (example of an exceptional case supporting general jurisdiction)
Pope v. Atlantic Coast Line R. Co., 345 U.S. 379 (FELA jurisdictional contexts)
Miles v. Illinois Central R. Co., 315 U.S. 698 (FELA jurisdictional contexts)
Denver & Rio Grande Western R. Co. v. Terte, 284 U.S. 284 (commerce clause and forum considerations)
Green v. Chicago, B. & Q. R. Co., 205 U.S. 530 (historical treatment of venue vs. personal jurisdiction)