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BNSF Railway v. Tyrrell

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Supreme Court of the United States
BNSF Railway v. Tyrrell
Reference: 16-405
Issue: Jurisdiction
Term: 2016
Important Dates
Argued: April 25, 2017
Decided: May 30, 2017
Outcome
Montana Supreme Court reversed and remanded
Vote
8-1 to reverse and remand
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Elena Kagan • Neil Gorsuch
Concurring
Sonia Sotomayor (in part)
Dissenting
Sonia Sotomayor (in part)


BNSF Railway v. Tyrrell is a case that was argued during the October 2016 term of the U.S. Supreme Court. Argument in the case was held on April 25, 2017. The case came on a writ of certiorari to the Montana Supreme Court. On May 30, 2017, in an opinion by Justice Ruth Bader Ginsburg, the court reversed and remanded the judgment of the Montana Supreme Court. Justice Sonia Sotomayor concurred in part and dissented in part from the court's opinion. The opinion was the first delivered for a case this term in which Justice Neil Gorsuch participated in oral arguments as a sitting justice.

In this case, the court held that provisions of the Federal Employers' Liability Act (FELA) do not allow state courts to exercise general personal jurisdiction over claims that are outside of any activity occurring within that state.

HIGHLIGHTS
  • The case: The estate of a Montana resident brought a civil action in Montana court against BNSF Railway (BNSF) claiming work-related injuries precipitated the resident's death. No alleged injuries occurred in Montana. BNSF filed to dismiss the case arguing the Montana court lacked jurisdiction. A Montana lower court and the Montana Supreme Court disagreed, holding that jurisdiction was conferred by Montana law and the Federal Employers' Liability Act (FELA).
  • The issue: Does the FELA confer jurisdiction to a state court over a case against an out-of-state railroad alleging injuries that did not occur in the state where the case was filed?
  • The outcome: The appeal is pending adjudication before the U.S. Supreme Court.


    • In brief: Alleging injuries that occurred during the course and scope of his work for BNSF Railway (BNSF) that ultimately led to his death, the estate of Brent Tyrrell filed suit against BNSF in a Montana state court. BSNF moved to dismiss the case claiming the Montana court lacked jurisdiction. None of the alleged injuries occurred in Montana and BNSF is neither incorporated nor headquartered in Montana. A lower court dismissed BNSF's motion and the Montana Supreme Court affirmed, holding that jurisdiction was conferred by Montana law and the Federal Employers' Liability Act (FELA). Argument in the case was held on April 25, 2017.

    You can review the lower court's opinion here.[1]

    Click on the tabs below to learn more about this Supreme Court case.

    Case

    Background

    In May of 2014, Kelli Tyrrell, in her capacity as special administrator for her late husband's estate, sued BSNF Railway (BNSF) in a Montana state court for injuries that Brent Tyrrell allegedly sustained during the course and scope of his work for BNSF. The complaint alleged that Tyrrell's work for BNSF exposed him to various carcinogenic chemicals that precipitated a terminal case of kidney cancer and ultimately led to his death. The complaint, however, did not allege that Tyrrell ever worked in Montana for BNSF or that he was exposed to any of the alleged carcinogenic chemicals in Montana.

    BNSF filed a motion to dismiss Tyrrell's complaint for lack of jurisdiction. The lower court judge denied BNSF's motion. In so doing, the judge relied on court precedent interpreting the Federal Employers' Liability Act (FELA) as allowing jurisdiction in the case because of BNSF's extensive activities in Montana. BNSF appealed to the Montana Supreme Court. In his opinion for the court, Judge James Jeremiah Shea affirmed the lower court order noting jurisdiction. In his interpretation of FELA, Judge Shea wrote,[1]

    “

    The U.S. Supreme Court consistently has interpreted 45 U.S.C. §56 to allow state courts to hear cases brought under the FELA even where the only basis for jurisdiction is the railroad doing business in the forum state. ... BNSF contends that Daimler ... overruled prior U.S. Supreme Court precedent holding the FELA conferred jurisdiction to state courts where the railroad does business. ... Daimler addressed 'the authority of a court in the United States to entertain a claim brought by foreign plaintiffs against a foreign defendant based on events occurring entirely outside the United States.' ... Unlike the cases before us, Daimler did not involve a FELA claim or a railroad defendant. Likewise, none of the cases BNSF cites to support its position that Daimler precludes state court jurisdiction over FELA claims against railroads involved FELA claims or railroad defendants. In Daimler, the U.S. Supreme Court did not address personal jurisdiction under the FELA, nor did it need to ...

    Moreover, Daimler did not present novel law. Rather, the U.S. Supreme Court emphasized prior holdings that general jurisdiction requires foreign corporations to have affiliations so 'continuous and systematic' as to render them 'at home' in the forum state. ... Congress drafted the FELA to make a railroad 'at home' for jurisdictional purposes wherever it is 'doing business.' ... Therefore, Daimler did not overrule decades of consistent U.S. Supreme Court precedent dictating that railroad employees may bring suit under the FELA wherever the railroad is 'doing business.'[2]

    		”

    Judge Shea then affirmed the finding made by the lower court that BNSF conducted business in Montana and, accordingly, Tyrrell's action against BNSF could be adjudicated by a Montana court.[1]

    Petitioner's challenge

    BNSF Railway, the petitioner, challenged the holding of the Montana Supreme Court that a Montana court has jurisdiction under the Federal Employers' Liability Act (FELA) to adjudicate Tyrrell's lawsuit.

    Certiorari granted

    On September 28, 2016, BNSF Railway, the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the Montana Supreme Court. The U.S. Supreme Court granted BNSF's certiorari request on January 13, 2017. Argument in the case was held on April 25, 2017.[3]

    Arguments


    Question presented

    Question presented:

    "Whether a state court may decline to follow this Court's decision in Daimler AG v. 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."[3]


    Audio

    • Audio of oral argument:[4]



    Transcript

    • Transcript of oral argument:[5]

    Outcome

    Decision

    Justice Ruth Bader Ginsburg delivered the opinion of the court. The court held that provisions of the Federal Employers' Liability Act (FELA) do not allow state courts to exercise general personal jurisdiction over claims that are outside of any activity occurring within that state. Justice Sonia Sotomayor concurred in part and dissented in part from the court's opinion. The opinion was the first delivered for a case this term in which Justice Neil Gorsuch participated in oral arguments as a sitting justice. [6]

    Opinion

    In her opinion for the court, Justice Ginsburg stipulated that both the respondents and the Montana Supreme Court were in error in interpreting 45 U.S.C. §56 tp confer personal jurisdiction to state courts for alleged injuries occurring out of state. She stated that "the Fourteenth Amendment's Due Process Clause does not permit a State to hale an out-of-state corporation before its courts when the corporation is not 'at home' in the State and the episode-in-suit occurred elsewhere."

    Justice Ginsburg next addressed the question of whether Montana's rules of civil procedure granted the state jurisdiction over the claims made against BNSF. Justice Ginsburg here said that the exercise of jurisdiction under state law was unfounded. She wrote,[6]

    “

    Because FELA does not authorize state courts to exercise personal jurisdiction over a railroad solely on the ground that the railroad does some business in their States, the Montana courts’ assertion of personal jurisdiction over BNSF here must rest on Mont. Rule Civ. Proc. 4(b)(1), the State’s provision for the exercise of personal jurisdiction over 'persons found' in Montana. ... BNSF does not contest that it is 'found within' Montana as the State’s courts comprehend that rule. We therefore inquire whether the Montana courts’ exercise of personal jurisdiction under Montana law comports withthe Due Process Clause of the Fourteenth Amendment. ...
    BNSF, we repeat, is not incorporated in Montana and does not maintain its principal place of business there. Nor is BNSF so heavily engaged in activity in Montana 'as to render [it] essentially at home' in that State. ... the business BNSF does in Montana is sufficient to subject the railroad to specific personal jurisdiction in that State on claims related to the business it does in Montana. But instate business, we clarified in Daimler and Goodyear, does not suffice to permit the assertion of general jurisdiction over claims like Nelson’s and Tyrrell’s that are unrelated to any activity occurring in Montana.[2]

    		”

    As a result of the court's opinion, the judgment of the Montana Supreme Court was reversed and the case was remanded.

    Concurring opinions

    Justice Sonia Sotomayor filed an opinion concurring in part with, and dissenting in part from, the court's judgment in this case. Justice Sotomayor concurred with the court that the Federal Employers' Liability Act (FELA) did not confer personal jurisdiction to state courts in cases involving railroads. She further concurred with the court that "the Montana Supreme Court erred when it concluded that the nature of the claim here—a FELA claim against a railroad—answers the question whether the Due Process Clause allows the exercise of personal jurisdiction over BNSF."[6]

    Dissenting opinions

    Justice Sonia Sotomayor filed an opinion concurring in part with, and dissenting in part from, the court's judgment in this case. Justice Sotomayor dissented from the court's rule, established in Daimler AG v. Bauman, that courts have general jurisdiction over corporate defendants only in states where the corporation is either incorporated or does a sufficient degree of commercial activity to be considered at-home in the state. In Justice Sotomayor's view, this placed a burden on individual plaintiffs. She wrote,[6]

    “

    The majority’s approach grants a jurisdictional windfall to large multistate or multinational corporations that operate across many jurisdictions. Under its reasoning, it is virtually inconceivable that such corporations will ever be subject to general jurisdiction in any location other than their principal places of business or of incorporation. Foreign businesses with principal places of business outside the United States may never be subject to general jurisdiction in this country even though they have continuous and systematic contacts within the United States. ... What was once a holistic, nuanced contacts analysis backed by considerations of fairness and reasonableness has now effectively been replaced by the rote identification of a corporation’s principal place of business or place of incorporation. The result? It is individual plaintiffs, harmed by the actions of a farflung foreign corporation, who will bear the brunt of the majority’s approach and be forced to sue in distant jurisdictions with which they have no contacts or connection. ... The focus should be on the quality and quantity of the defendant’s contacts in the forum State. ...
    This result is perverse. Despite having reserved the possibility of an 'exceptional case' in Daimler, the majority here has rejected that possibility out of hand. Worse, the majority reaches its conclusion only by departing from the Court’s normal practice. Had it remanded to the Montana Supreme Court to reevaluate the due process question under the correct legal standard, that court could have examined whether this is such an 'exceptional case.' Instead, with its ruling today, the Court unnecessarily sends a signal to the lower courts that the exceptional-circumstances inquiry is all form, no substance.[2]

    		”


    The opinion

    Filings

    The U.S. Supreme Court granted BNSF's certiorari request on January 13, 2017.

    Merits filings

    Parties' briefs

    • BNSF Railway, the petitioner, filed a merits brief on February 27, 2017.
    • Kelli Tyrrell, as special administrator for the estate of Brent T. Tyrell (deceased), et al. filed a merits brief on March 29, 2017.

    Amicus curiae briefs

    The following groups filed amicus curiae briefs in support of the petitioner in this case, BNSF Railway:

    • Brief of the Association of American Railroads
    • Brief of the National Association of Manufacturers
    • Brief of Professor Stephen E. Sachs
    • Brief of the United States of America

    The following groups filed amicus curiae briefs in support of the respondents in this case, Kelli Tyrrell et al.:

    • Brief of the Academy of Rail Labor Attorneys
    • Brief of the American Association for Justice
    • Brief of the Brotherhood of Maintenance of Way Employees Division/IBT

    Certiorari filings

    Parties' filings

    • BNSF Railway, the petitioner, filed a petition for a writ of certiorari on September 28, 2016.
    • Kelli Tyrrell, as special administrator for the estate of Brent T. Tyrell (deceased), et al. filed a brief in opposition to certiorari on November 28, 2016, after an order extending the time to file was granted.

    Amicus curiae filings

    The following groups filed amicus curiae briefs in support of granting certiorari:

    • Brief of the American Association of Railroads
    • Brief of the National Association of Manufacturers

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of Montana, Kelli Tyrrell, as Special Administrator for the Estate of Brent T. Tyrrell (deceased), et al. v. BNSF Railway Co., filed May 31, 2016
    2. ↑ 2.0 2.1 2.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    3. ↑ 3.0 3.1 Supreme Court of the United States, BNSF Railway Co. v. Tyrrell, January 13, 2017
    4. ↑ Supreme Court of the United States, BNSF R. Co. v. Tyrrell, argued April 25, 2017
    5. ↑ Supreme Court of the United States, BNSF R. Co. v. Tyrrell, argued April 25, 2017
    6. ↑ 6.0 6.1 6.2 6.3 Supreme Court of the United States, BNSF Railway Co. v. Tyrrell, decided May 30, 2017
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