Term: 2016
Docket: 16-405
Bnsf Railway Co. v. Tyrrell
- Pro
16-405 BNSF RAILWAY CO. V. TYRRELL DECISION BELOW: 373 P.3d 1 CERT. GRANTED 1/13/2017 QUESTION PRESENTED: In Daimler AG v. Bauman, 134 S. Ct. 746 (2014), this Court held that the Due Process Clause forbids a state court from exercising general personal jurisdiction except where the defendant is "at home." BNSF Railway Company is not at home in Montana under Daimler, yet the Montana Supreme Court held that BNSF is subject to general personal jurisdiction in Montana, and can be sued there by out-of-state plaintiffs for claims that have no connection at all to the state. The Montana Supreme Court explicitly "declined" to apply this Court's decision in Daimler, for two reasons: First, because the facts of this case involve American parties and arose in the United States, not foreign parties and an overseas injury as in Daimler. Second, because the plaintiffs here sued under the Federal Employers' Liability Act (FELA), which is a different federal cause of action from the ones at issue in Daimler. Section 56 of FELA establishes venue for cases filed in federal court, and it provides for concurrent subject-matter jurisdiction in state courts. Yet the Montana Supreme Court held that this provision authorizes state courts to exercise personal jurisdiction, and that the statute overrides the limitations of the Due Process Clause. The question presented is: Whether a state court may decline to follow this Court's decision in Daimler AG u. Bauman, which held that the Due Process Clause forbids a state court from exercising general personal jurisdiction over a defendant that is not at home in the forum state, in a suit against an American defendant under the Federal Employers' Liability Act. LOWER COURT CASE NUMBER: DA 14-0825
The U.S. Supreme Court case BNSF Railway Co. v. Tyrrell, 2016 revolved around the issue of jurisdiction and whether a state court can hear cases against companies that are not based in their state but do business there. The plaintiffs were two employees who filed suits for injuries sustained while working for BNSF Railway Company, which is incorporated in Delaware and has its principal place of business in Texas but operates railroad tracks across many states including Montana where the lawsuits were filed. However, neither plaintiff resided nor was injured in Montana; one lived and was injured in North Dakota while the other lived and was injured in South Dakota. BNSF argued that it should not be subject to personal jurisdiction because it did not have sufficient contacts with Montana related to these specific claims as required by Fourteenth Amendment's Due Process Clause. In an 8-1 decision, the Supreme Court sided with BNSF stating that under Daimler AG v Bauman (2014), a corporation is only subject to general personal jurisdiction - i.e., being sued on any matter regardless of where it occurred - if they are "at home" which typically means either their place of incorporation or main office unless exceptional circumstances exist.
In the dissenting opinion for BNSF Railway Co. v. Tyrrell, Justice Sotomayor argued that the majority's decision was too restrictive and could potentially limit plaintiffs' access to justice in state courts. She disagreed with the majority's interpretation of Daimler AG v. Bauman, asserting it should not apply to all cases where a corporation is sued in a state where it is not 'at home.' Instead, she believed there should be exceptions when specific claims arise from a company’s activities within that particular state or if there are compelling reasons why trial must proceed there. The ruling, according to her view, would unfairly burden injured parties by forcing them to sue large corporations only in their principal place of business or incorporation even though they may have substantial operations elsewhere.
