BNSF Ry. Co. v. Tyrrell
581 U.S. 402
SCOTUS2017Background
- Two FELA suits were filed in Montana state court by nonresident plaintiffs (Nelson from North Dakota; Tyrrell as administrator for decedent Brent Tyrrell) for injuries unrelated to work in Montana.
- Defendant BNSF is incorporated in Delaware with its principal place of business in Texas; it operates in 28 states and maintains about 2,061 miles of track and ~2,100 employees in Montana (small percentages of its total operations).
- Montana Supreme Court held Montana courts had general personal jurisdiction over BNSF under 45 U.S.C. § 56 (railroads "doing business" in the State) and Montana Rule Civ. Proc. 4(b)(1) ("persons found within").
- Montana court rejected Daimler as inapplicable because FELA and railroad status, and treated § 56 as authorizing jurisdiction in state courts.
- Supreme Court granted certiorari to decide whether § 56 authorizes state-court personal jurisdiction over railroads doing business in a State and whether Montana’s exercise of jurisdiction satisfies the Due Process Clause.
Issues
| Issue | Plaintiffs' Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 45 U.S.C. § 56 authorizes state courts to exercise personal jurisdiction over a railroad "doing business" in the State | §56 allows suit where defendant is doing business; its "concurrent jurisdiction" language extends that to state courts | §56 is a federal venue provision and its "concurrent jurisdiction" clause addresses subject-matter jurisdiction, not personal jurisdiction | §56 does not confer personal jurisdiction; its first sentence concerns federal-court venue and its second sentence preserves concurrent subject-matter jurisdiction for state courts |
| Whether Montana’s assertion of general personal jurisdiction over BNSF comports with the Due Process Clause (Daimler standard) | FELA/railroad status and substantial in-state operations justify general jurisdiction in Montana | BNSF is not "at home" in Montana (not incorporated or principal place of business there); Daimler limits general jurisdiction to places where a corporation is essentially at home | Montana’s exercise of general jurisdiction violated the Due Process Clause under Daimler; BNSF is not "at home" in Montana |
| Whether BNSF consented to personal jurisdiction in Montana | Plaintiffs argued BNSF consented | BNSF disputed consent | Not reached by Supreme Court (Montana court did not rely on consent) |
Key Cases Cited
- Daimler AG v. Bauman, 571 U.S. 117 (clarifying general-jurisdiction "at home" standard)
- International Shoe Co. v. Washington, 326 U.S. 310 (establishing minimum-contacts due process framework)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (discussing general jurisdiction and "continuous and systematic" contacts)
- Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (example of an "exceptional case" for general jurisdiction)
- Baltimore & Ohio R. Co. v. Kepner, 314 U.S. 44 (interpreting FELA venue provision as venue, not personal jurisdiction)
- Miles v. Illinois Central R. Co., 315 U.S. 698 (related FELA venue/state-court jurisdiction decision)
- Pope v. Atlantic Coast Line R. Co., 345 U.S. 379 (state-court injunctions and FELA suits)
- Denver & Rio Grande Western R. Co. v. Terte, 284 U.S. 284 (addressing Commerce Clause and forum concerns in FELA context)