Where companies can be sued
BNSF R. v. Tyrrell
In brief
The Supreme Court ruled that Montana could not use general jurisdiction to hear the workers’ claims against BNSF.
- Where it stands
- Decided
Decided 8-1 · May 30, 2017 · Opinion by Justice Ginsburg
- What it’s about
- The Court ruled the Federal Employers’ Liability Act (FELA) does not give state courts personal jurisdiction (authority over a defendant), and Montana could not constitutionally exercise it over BNSF because neither worker alleged a Montana-related injury.
- Who it affects
- In these cases, Montana courts cannot rely on general jurisdiction to hear Nelson’s and Tyrrell’s FELA claims against BNSF.
Summary: written with AI from the case record.
What it's about
It overturned the Montana Supreme Court’s ruling and sent both cases back to the lower court (remanded).
Neither Nelson nor Tyrrell alleged that his injury came from work in or was otherwise related to Montana.
The case involved claims under a federal railroad law, but the Court also had to decide whether the Constitution allowed Montana courts to hear those claims against BNSF.
Question presented
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.
What the Court decided
Holding
The Montana courts’ exercise of personal jurisdiction under Montana law does not comport with the Fourteenth Amendment’s Due Process Clause. Only the propriety of general personal jurisdiction is at issue here because neither Nelson nor Tyrrell alleges injury from work in or related to Montana. A state court may exercise general jurisdiction over out-of-state corporations when their “affiliations with the State are so ‘continuous and systematic’ as to render them essentially at home in the forum State.” Daimler, 571 U. S., at ___. 383 Mont. 417, 373 P. 3d 1, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said FELA itself does not give state courts authority over railroads. Because neither worker alleged a Montana-related injury, only general jurisdiction was at issue; the Court said that power applies to an out-of-state company only when its ties make it essentially at home in the state.
The vote
From the opinions
“And even if the Court insists on adhering to that standard, I dissent from its decision to apply it here in the first instance rather than remanding to the Montana Supreme Court for it to conduct what should be a fact-intensive analysis under the proper legal framework.”
What's next
The Montana Supreme Court must take up the two cases again under the Supreme Court’s ruling.
Documents
Docket activity
New analysis added
AI analysis generated: Impact Analysis
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
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Case data updated: question_presented, extraction_metadata
Opinion added: Tyrrell
Brief added: Questions Presented
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.