BNSF Railway Co. v. Tyrell
United States Supreme Court
137 S. Ct. 1549 (2017)
Two separate plaintiffs, Robert Nelson and Kelli Tyrell (representing her late husband's estate), sued BNSF Railway (defendant) in Montana state court under the Federal Employers' Liability Act (FELA) for work-related injuries, neither of which arose from work performed in Montana. BNSF, a Delaware corporation headquartered in Texas, had about 2,000 miles of track (6% of its national total) and 2,100 employees (5% of its workforce) in Montana. BNSF moved to dismiss both suits for lack of general personal jurisdiction. The trial court split the two cases, and the Montana Supreme Court consolidated them and held Montana courts had general jurisdiction because FELA authorizes suit where a railroad is "doing business" and Montana's procedural rules reach anyone "found within" the state. The U.S. Supreme Court granted certiorari.
Whether a state court may exercise general personal jurisdiction over a railroad based solely on the railroad's track mileage and employees in the state when those in-state activities are not so continuous and systematic as to render the railroad at home there.