Summary
The Supreme Court held that § 56 of the Federal Employers’ Liability Act addresses federal-court venue and concurrent subject-matter jurisdiction, not personal jurisdiction over railroads. The Court further held that Montana could not exercise general personal jurisdiction over BNSF for claims unrelated to the railroad’s activities in Montana because BNSF was not “at home” there under the Due Process Clause. The judgment of the Montana Supreme Court was reversed and the cases were remanded.
Topics
Practice areas
Questions Presented
- Whether § 56 of the Federal Employers' Liability Act authorizes state courts to exercise personal jurisdiction over railroads merely because they are doing business in the State.
- Whether the second sentence of FELA § 56, providing for concurrent jurisdiction of federal and state courts, concerns personal jurisdiction or subject-matter jurisdiction.
- Whether Montana's exercise of general personal jurisdiction over BNSF, based on its substantial business activities in Montana unrelated to the plaintiffs' claims, complied with the Fourteenth Amendment's Due Process Clause.
Holdings
- FELA § 56 does not authorize personal jurisdiction over railroads based merely on their doing business in a State. The first relevant sentence is a federal-court venue provision, not a grant of personal jurisdiction.
- The second relevant sentence of FELA § 56 refers to concurrent subject-matter jurisdiction, not personal jurisdiction. It confirms that state courts may hear FELA claims concurrently with federal courts.
- Montana's exercise of general personal jurisdiction over BNSF violated the Fourteenth Amendment because BNSF was not at home in Montana and the claims were unrelated to its Montana activities.
Key quotations
“We hold that § 56 does not address personal jurisdiction over railroads.” (1554)
“A corporation that operates in many places can scarcely be deemed at home in all of them.” (1559)
“In short, the business BNSF does in Montana is sufficient to subject the railroad to specific personal jurisdiction in that State on claims related to the business it does in Montana.” (1559)
Factual background
Robert Nelson, a North Dakota resident, sued BNSF under FELA for knee injuries allegedly sustained while working as a fuel-truck driver. Kelli Tyrrell, administrator of her husband's estate, sued BNSF alleging that Brent Tyrrell developed fatal kidney cancer from exposure to carcinogenic chemicals while working for BNSF. Neither plaintiff alleged an injury arising from work performed in Montana. BNSF was incorporated in Delaware and headquartered in Texas, although it operated 2,061 miles of track and employed approximately 2,100 workers in Montana.
Procedural history
Nelson and Tyrrell filed separate FELA actions against BNSF in Montana state courts, although neither alleged an injury arising from work performed in Montana. BNSF's jurisdictional motion was granted in Nelson's case and denied in Tyrrell's. The Montana Supreme Court consolidated the cases and held that Montana courts could exercise general personal jurisdiction over BNSF under FELA and Montana law. The Supreme Court reversed and remanded.
Remand instructions
The cases were remanded for further proceedings not inconsistent with the opinion.