Civil Procedure
BNSF Railway Co. v. Tyrrell, 581 U.S. ___, 137 S. Ct. 1549, 198 L. Ed. 2d 36 (2017) (U.S. Supreme Court)
Study notes for BNSF Railway Co. v. Tyrrell: professor notes, cold call prep, exam angles, and memory aids.
FELA does not provide personal jurisdiction over railroads in a state where they do business when the claims do not arise from their in-state activities.
In BNSF Railway Co. v. Tyrrell, the Supreme Court clarified the boundaries of personal jurisdiction in the context of the Federal Employers' Liability Act (FELA). The Court emphasized that FELA §56 does not grant broader personal jurisdiction to state courts over railroads than what is permissible under the Due Process Clause. This distinction is crucial for understanding how federal statutes interact with state court jurisdiction and the necessity for plaintiffs to establish sufficient connections between the forum state and the defendant corporation. The ruling signals caution against assuming a broader scope of jurisdiction based solely on a corporation's business operations in a state.
The decision further underscores the significance of the 'at home' standard for determining general jurisdiction, derived from the landmark case Goodyear Dunlop Tires Operations, S.A. v. Brown. Since BNSF's principal place of business is in Texas and the claims arose from activities unrelated to Montana, the Court ruled that Montana lacked jurisdiction over these claims. This case thus illustrates the continuing evolution of personal jurisdiction law and the implications for out-of-state corporate defendants in various jurisdictions.
BNSF: Business Not Subject to Forum (general jurisdiction not applicable)
| Case | Distinction |
|---|---|
| International Shoe Co. v. Washington | Different from BNSF, this case established the minimum contacts test for specific jurisdiction. |
| Goodyear Dunlop Tires Operations, S.A. v. Brown | BNSF is distinguished from Goodyear as the latter clarified the 'at home' standard for general jurisdiction, which BNSF did not meet. |
| Shaffer v. Heitner | This case involved questions of statutory jurisdiction and distinguished between traditional notions of jurisdiction and modern interpretations, showing how expansively or restrictively jurisdiction can be approached. |
The rule protects corporations from having to face suits in jurisdictions where they have minimal contacts, promoting fairness and predictability.
Critics might argue that this limits access to justice for injured parties by preventing them from suing in more conveniently located jurisdictions.
This case typically appears on exams in the context of evaluating personal jurisdiction challenges and understanding the implications of federal statutes on state court actions.