BNSF Railway Co. v. Tyrrell

§56 of the Federal Employers’ Liability Act does not confer to the States the power to exercise personal jurisdiction over nonresident corporations that are not “at home” in the putative forum state.

Respondents were an employee of the Petitioner, a railroad company, and a widow of a deceased employee. Respondents sued Petitioner in Montana for work related injuries pursuant to the Federal Employers’ Liability Act, 35 Stat. 65, as amended, 45 U. S. C. §51 et seq. (“FELA”). Petitioner moved to dismiss both lawsuits on the basis of lack of personal jurisdiction. After one case was dismissed and the other was not, the Supreme Court of Montana consolidated the cases and held that §56 of the FELA conferred personal jurisdiction over railroads doing business in the state. The U.S. Supreme Court reviewed the statutory language of §56. The Court determined that §56 refers to subject matter jurisdiction and venue; not personal jurisdiction. The Court then applied its Goodyear and Daimler personal jurisdiction analysis, which sought to determine whether the entity had “continuous and systematic” contacts that made it “essentially at home” in the state. Because Petitioner was not “heavily engaged in activity” in Montana, and it was not incorporated or headquartered there, the Court determined that Montana did not have personal jurisdiction over the Petitioner. The Court remanded for further review of whether Petitioner consented to personal jurisdiction. REVERSED and REMANDED.