Mallory v. Norfolk Southern R.
In brief
The Court said Pennsylvania's registration-based consent does not violate due process, but wiped out the Pennsylvania judgment (vacated it) and sent Mallory's case back (remanded it).
- Where it stands
- Decided
Decided 5-4 · June 27, 2023 · Opinion by Justice Jackson
- What it’s about
- Robert Mallory sued Norfolk Southern Railway in Pennsylvania for workplace injuries that occurred in other states.
- Who it affects
- The ruling says Pennsylvania's registration law can support suits against registered out-of-state companies even when injuries happened elsewhere.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that a Pennsylvania law requiring out-of-state companies to consent to face lawsuits in the state as a condition of doing business there does not violate the Due Process Clause.
States require out-of-state companies to register before doing business, and this case asks whether that requirement can also open the door to lawsuits unrelated to the state.
Question presented
Does a state registration statute for out-of-state corporations that purports to confer general personal jurisdiction over the registrant violate the Due Process Clause of the Fourteenth Amendment?
What the Court decided
Holding
The judgment is vacated, and the case remanded. This case is controlled by Pennsylvania Fire Ins. Co. of Philadelphia v. Gold Issue Mining & Milling Co., 243 U. S. 93. Much like the Missouri law that the Court in Pennsylvania Fire found to comport with the Due Process Clause, the Pennsylvania law at issue here provides that an out-ofstate corporation “may not do business in this Commonwealth until it registers with” the Department of State. 15 Pa. Cons. Stat. §411(a).
- Result
- Vacated
The vote
- Joined the judgment
- Dissented
- Wrote an opinion
- Majority · 5joined the Court's opinion
From the opinions
“By relabeling their long-arm statutes, States may now manufacture “consent” to personal jurisdiction.”
What's next
The Pennsylvania court will continue the case under the Supreme Court's directions. The final outcome of Mallory's injury claims remains unresolved.
Why it matters
Because the Court wiped out the Pennsylvania judgment and sent the case back, Mallory's final injury claims remain unresolved.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
New analysis added
New analysis added
Show 6 moreShow fewer
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
Case data updated: status, opinion_date
Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
More questions
- What was Mallory v. Norfolk Southern about?
- Robert Mallory sued Norfolk Southern in Pennsylvania for injuries that occurred in other states. The case asks whether registering to do business there counts as agreeing to be sued there.
- What did the Supreme Court decide about Pennsylvania's registration rule?
- The Court said treating registration as consent to the court's power over Norfolk Southern (personal jurisdiction) does not violate due process.
- What happened to the Pennsylvania judgment in Mallory?
- The Court wiped out the judgment (vacated it) and sent the case back to the Pennsylvania court (remanded it) for further proceedings.
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.