402 P.3d 1213
Mont.2017Background
- Decedent Zachary Buckles died on April 28, 2014 while manually gauging crude-oil tanks at Continental’s Columbus Federal 2-16H well site in North Dakota. The site was overseen from Continental’s Sidney, Montana office.
- Buckles’ estate sued Continental (an Oklahoma corporation doing substantial business in Montana) and Montana subcontractors, alleging they jointly maintained an unsafe well site and failed to provide adequate monitoring/training.
- Procedural history: Buckles filed in Montana state court; Continental moved to dismiss for lack of personal jurisdiction after limited jurisdictional discovery. The District Court granted the motion in a brief order without an evidentiary hearing or factual findings.
- Continental conceded its Sidney office had oversight responsibility for the wells, but asserted it did not direct or control the contractors’ tank-gauging employees and that contractors (not Continental) performed and directed those tasks.
- The Montana Supreme Court reversed the dismissal as to Continental, holding that disputed jurisdictional facts exist and remanding for an evidentiary hearing on specific personal jurisdiction (general jurisdiction rejected under Daimler/Tyrrell).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| General personal jurisdiction — is Continental “at home” in Montana? | Continental’s extensive Montana operations (wells, offices, vehicles, registered business) make it subject to general jurisdiction. | Continental is incorporated and headquartered in Oklahoma; being active in Montana does not render it “at home” there. | No general jurisdiction: Continental is not "at home" in Montana under Daimler/Tyrrell. |
| Specific personal jurisdiction — do Continental’s Montana contacts create suit-related ties? | Sidney office oversaw the well and Continental jointly caused/allowed an unsafe site; those forum-related activities give rise to Buckles’ claim. | Oversight does not equal direction/control of gauging; contractors (not Continental) performed the tortious conduct; contacts are with subcontractors, not suit-related acts by Continental in Montana. | Reversed dismissal; specific jurisdiction unresolved because material jurisdictional facts are disputed. Court ordered remand for an evidentiary (preliminary) hearing to resolve jurisdictional facts. |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishes the minimum-contacts due process test for personal jurisdiction)
- Daimler AG v. Bauman, 571 U.S. 117 (2014) (limits general jurisdiction to a corporation’s place of incorporation or principal place of business except in exceptional circumstances)
- BNSF Ry. Co. v. Tyrrell, 137 S. Ct. 1549 (2017) (reinforces that extensive in-state operations do not automatically permit general jurisdiction when the defendant is not "at home")
- Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (specific jurisdiction requires an affiliation between the forum and the underlying controversy)
- Walden v. Fiore, 134 S. Ct. 1115 (2014) (a defendant’s forum contacts, not the unilateral activity of third parties, are central to specific-jurisdiction analysis)
- Goodyear Dunlop Tires Operations, S. A. v. Brown, 564 U.S. 915 (2011) (clarifies limits on general jurisdiction for corporations)