Estate of Buckles
2017 MT 235
| Mont. | 2017Background
- Zachary Buckles died on April 28, 2014 from hydrocarbon vapor exposure while manually gauging crude oil tanks at Continental’s Columbus Federal 2-16H well site in North Dakota.
- Continental Resources, an Oklahoma corporation, operates and oversees the subject well site from its Sidney, Montana office and has substantial Montana operations (wells, field offices, vehicles, and property).
- Buckles’ estate sued Continental and several Montana subcontractors, alleging failure to maintain a safe well site and to provide proper training/air-monitoring, and asserting joint/agency theories of liability.
- Continental moved to dismiss for lack of personal jurisdiction. The District Court granted the motion in a short order without factual findings after limited jurisdictional discovery.
- The Montana Supreme Court reversed, holding that (1) general jurisdiction over Continental in Montana is not available under Daimler/Tyrrell, but (2) the complaint and limited discovery raised factual disputes sufficient to warrant an evidentiary hearing on specific personal jurisdiction because Buckles’ suit-related allegations connect Continental’s Sidney office to operation/oversight of the well site.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Montana has general jurisdiction over Continental | Buckles argued Continental’s extensive Montana operations subject it to jurisdiction | Continental is incorporated and P.O.B. in Oklahoma and not "at home" in Montana | No general jurisdiction (Daimler/Tyrrell) |
| Whether Montana has specific jurisdiction over Continental under M. R. Civ. P. 4(b)(1) | Buckles: Sidney office oversaw the well site and, jointly with Montana co-defendants, caused unsafe conditions giving rise to the claim | Continental: oversight does not include directing contractors’ gauging work; liability rests with subcontractors; contracts disclaim agency | Specific jurisdiction not decided on the pleadings; remanded for evidentiary hearing because disputed jurisdictional facts exist |
| Whether a district court may resolve jurisdiction when jurisdictional facts are disputed | Buckles sought to rely on pleadings and limited discovery | Continental relied on affidavits and contract language asserting lack of suit-related conduct in Montana | Where material jurisdictional facts are in dispute, court must hold a preliminary evidentiary hearing (or otherwise allow proof) before dismissal |
| Whether plaintiff’s joint/agency allegations improperly conflate third-party contacts with defendant contacts | Buckles alleged joint action/agency sufficient to tie Continental to Montana-related conduct | Continental argued plaintiff cannot base jurisdiction on contacts of third parties or subcontractors alone (Walden/Helicopteros) | Court: plaintiff’s allegations and limited discovery plausibly link Continental’s Montana oversight to the suit-related conduct; merits questions go to liability and cannot be resolved at jurisdictional dismissal stage |
Key Cases Cited
- Daimler AG v. Bauman, 571 U.S. _, 134 S. Ct. 746 (2014) (general-jurisdiction standard; corporation subject to general jurisdiction only where "at home").
- BNSF Ry. v. Tyrrell, 137 S. Ct. 1549 (2017) (reiterating Daimler limits on general jurisdiction over large, multi-state corporations).
- Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (specific-jurisdiction requires suit to arise out of or relate to defendant’s forum contacts).
- Walden v. Fiore, 134 S. Ct. 1115 (2013) (contacts of plaintiff or third parties cannot substitute for defendant’s own forum contacts for jurisdictional purposes).
- Data Disc, Inc. v. Systems Tech. Assoc., Inc., 557 F.2d 1280 (9th Cir. 1977) (procedure for resolving jurisdictional facts intertwined with merits; prelim evidentiary hearing and burdens).
- Simmons v. State, 206 Mont. 264, 670 P.2d 1372 (1983) (Montana’s specific-jurisdiction factors: purposeful availment, claim arises from forum activities, reasonableness).
- Minuteman Aviation v. Swearingen, 237 Mont. 207, 772 P.2d 305 (1989) (where jurisdictional facts are disputed, district court should hold preliminary hearing under Rule 12).