BNSF Railway Co. v. Super. Ct.
235 Cal.App.4th 591
Cal. Ct. App.2015Background
- Plaintiffs (real parties) sued BNSF in Los Angeles for wrongful death from alleged asbestos exposure that occurred in Wichita, Kansas; BNSF is successor to the defendant entity implicated in plaintiffs’ claims.
- BNSF moved to quash service for lack of personal jurisdiction, arguing no specific jurisdiction (claims arose outside California) and no general jurisdiction (incorporated in Delaware; principal place of business in Texas).
- BNSF submitted uncontested corporate evidence: ~23,319 miles of track nationwide; California: ~1,149 miles (≈5% of track), ~3,520 employees (≈8% workforce), ≈6% of revenue; HQ and main operations hub in Fort Worth, Texas.
- Plaintiffs conceded substantial, continuous business contacts in California and sought jurisdictional discovery and to rely on additional public records to show general jurisdiction.
- The trial court denied the motion to quash, finding BNSF’s continuous and systematic California operations made it amenable to general jurisdiction; BNSF petitioned for writ of mandate.
- The Court of Appeal denied plaintiffs’ request for judicial notice of additional records, applied federal due-process principles on general jurisdiction, and granted the writ, holding California lacks general jurisdiction over BNSF.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether California may exercise general (all‑purpose) jurisdiction over BNSF | BNSF’s substantial, continuous, systematic contacts with California (employees, track, revenue) render it "essentially at home" and subject to general jurisdiction; jurisdictional discovery and public records would further show this | Daimler/Goodyear confine general jurisdiction to a corporation’s place of incorporation or principal place of business except in rare, exceptional cases; BNSF’s California contacts are substantial but constitute a small fraction of its nationwide operations | Court held no general jurisdiction: BNSF not "at home" in California; its California contacts are insufficient in the nationwide/worldwide context per Daimler/Goodyear |
| Whether the trial court should consider additional public records not presented below | Additional public records would show BNSF is effectively domestic in California and justify jurisdiction; Daimler’s contours warrant further examination | Appellate courts generally will not judicially notice evidence not presented to the trial court absent exceptional circumstances | Court denied judicial notice: plaintiffs had opportunity to present the evidence below and did not meet the exceptional‑circumstances standard |
| Whether plaintiffs met their burden to prove jurisdiction by a preponderance | Plaintiffs argued admissions and limited deposition evidence suffice and further discovery would support the case | BNSF argued plaintiffs failed to provide competent evidence to meet their burden and conceded contacts are immaterial under Daimler | Court: plaintiff failed to carry burden to show BNSF is "at home"; evidence considered was insufficient to establish general jurisdiction |
| Whether Daimler and Goodyear apply where defendant is U.S. company with significant in‑state operations | Plaintiffs argued differences in facts (domestic company; physical California operations) distinguish those precedents | BNSF argued Daimler/Goodyear are broadly applicable to limit general jurisdiction and avoid every‑state suits where nationwide operations exist | Court held Daimler/Goodyear apply broadly; factual differences do not create a categorical exception—only truly exceptional cases justify general jurisdiction outside incorporation or principal place of business |
Key Cases Cited
- Daimler AG v. Bauman, 134 S. Ct. 746 (clarified and limited corporate general jurisdiction; "at home" standard)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 131 S. Ct. 2846 (general jurisdiction requires affiliations so continuous and systematic as to render corporation "essentially at home")
- International Shoe Co. v. Washington, 326 U.S. 310 (minimum contacts and fair play standards foundational to jurisdiction analysis)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (paradigmatic case for general jurisdiction where forum is corporation’s principal place of business)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (distinguished continuous and systematic contacts that do not support general jurisdiction)