On May 30, 2017, the U.S. Supreme Court considered jurisdiction over railroads under the Federal Employers’ Liability Act (“FELA”). BNSF Railway Co. v. Tyrell, 581 U.S. _ (May 30, 2017) . Specifically, the Court addressed the decision of the Montana Supreme Court in which it found that the state could assert jurisdiction over BNSF Railway Company for a non-resident employee whose injury happened in another state. BNSF is not incorporated or headquartered in Montana. At issue were two potential sources of Montana jurisdiction (1) Section 56 of FELA, and (2) Montana’s jurisdictional statute. The Court considered and rejected both.
First, the Court analyzed Section 56 of FELA, which states that “an action may be brought in a district court of the United States,” in, among other places, the district “in which the defendant shall be doing business at the time of commencing such action” and “[t]he jurisdiction of the courts of the United States, under this chapter shall be concurrent with that the courts of the several States.” The Court held that the first portion of the Section 56 concerns federal court venue and confers no personal jurisdiction on any court, whereas the second portion refers merely to concurrent subject-matter jurisdiction of state and federal courts over actions under FELA. Accordingly, the Court found that FELA did not authorize Montana state court to assert personal jurisdiction over BNSF.
Second, the Court turned to Montana Rule of Civil Procedure 4(b)(1), which authorizes state courts to exercise personal jurisdiction over “persons found” in Montana. Specifically, the Court analyzed whether Montana’s rule comported with the Due Process Clause of the Fourteenth Amendment. Reviewing BNSF’s operations in Montana, the Court found that BNSF was not so heavily engaged in activity in Montana as to render it “at home” in that state, finding that mere in-state business does not suffice to establish general jurisdiction over claims unrelated to any activity occurring in Montana.
Accordingly, the Court reversed the Montana Supreme Court.
For a copy of the opinion, please click here.