Tyrrell v. BNSF Railway Co., 373 P.3d 1

Background

Two consolidated FELA suits against BNSF (Nelson and Tyrrell). Plaintiffs were injured while employed by BNSF outside Montana; complaints did not allege any Montana workplace or injury.
BNSF (Delaware corp.; principal place of business Texas) moved to dismiss both actions for lack of personal jurisdiction; one district judge denied (Tyrrell), another granted (Nelson).
Trial court denial (Tyrrell) adopted reasoning from a related Montana decision (Monroy) finding BNSF has substantial, continuous, systematic Montana operations (facilities, offices, employees, investment, licensed to do business).
Montana Supreme Court reviewed whether Montana courts have personal jurisdiction over BNSF under (1) the FELA (45 U.S.C. § 56) and (2) Montana law (M. R. Civ. P. 4(b)(1) and due process).
Majority held Montana courts have general personal jurisdiction over BNSF under both the FELA and Montana law; affirmed denial in Tyrrell, reversed dismissal in Nelson, and remanded.
A dissent argued Daimler and Goodyear control general-jurisdiction analysis under the Fourteenth Amendment and that BNSF is not "at home" in Montana, so due process forbids general jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Montana courts have personal jurisdiction over BNSF under the FELA	FELA §56 allows suit where the railroad is "doing business"; BNSF does business in Montana so Montana courts have general jurisdiction	Daimler and related due-process limits preclude treating "doing business" as sufficient for general jurisdiction	Held: Under FELA §56 and Supreme Court precedents interpreting the FELA, Montana courts have general personal jurisdiction over BNSF
Whether Montana courts have personal jurisdiction over BNSF under Montana law	Montana long-arm and M.R. Civ. P. 4(b)(1) permit general jurisdiction when a nonresident has substantial, continuous, systematic contacts	Due process (Fourteenth Amendment) blocks general jurisdiction absent defendant being "at home" in forum per Daimler	Held: BNSF’s extensive Montana operations satisfy M.R. Civ. P. 4(b)(1); exercising jurisdiction comports with due process under Montana precedent and FELA policy
Effect of Daimler on FELA-based venue/jurisdiction	FELA’s historical purpose and §56 permit broader forum selection than Daimler’s "at home" standard would allow	Daimler limits general jurisdiction nationwide and should preclude jurisdiction here	Held: Daimler does not control FELA §56 analysis; the Court applies FELA precedents (Miles, Kepner, Terte) and finds jurisdiction despite Daimler
Whether the Due Process Clause independently forbids jurisdiction	Plaintiffs argue due-process concerns are satisfied by BNSF’s Montana contacts and FELA policy favoring liberal forum choice	BNSF contends Fourteenth Amendment requires "at home" showing (Daimler/Goodyear) and Montana contacts are insufficient	Held: Majority concludes due process satisfied under Montana law given BNSF’s activities and historical FELA precedent; dissent disagrees, invoking Daimler

Key Cases Cited

Kepner v. Balt. & Ohio R.R. Co., 314 U.S. 44 (construing FELA §56 to allow suit where carrier is doing business)
Miles v. Illinois Cent. R.R. Co., 315 U.S. 698 (FELA permits suits in state courts where defendant is carrying on railroading in forum)
Pope v. Atlantic Coast Line R.R. Co., 345 U.S. 379 (FELA §56 creates transitory cause of action; plaintiff may sue where carrier does business)
Denver & Rio Grande W.R.R. Co. v. Terte, 284 U.S. 284 (distinguishing when railroads may be sued in forums based on in-state operations)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (general-jurisdiction "at home" standard)
Daimler AG v. Bauman, 571 U.S. 117 (reaffirming that general jurisdiction ordinarily limited to place of incorporation or principal place of business)
Urie v. Thompson, 337 U.S. 163 (FELA is to be liberally construed in favor of injured railroad employees)
Sinkler v. Mo. Pac. R.R. Co., 356 U.S. 326 (discussing FELA’s remedial purpose)