BNSF Railroad Co. v. Tyrrell

Two plaintiffs, Kelli Tyrrell and Nikki Tyrrell, sued BNSF Railway Company in Montana state court under the Federal Employers’ Liability Act (FELA), alleging their father developed fatal cancer from workplace exposures during his employment with BNSF. The railroad moved to dismiss for lack of personal jurisdiction, arguing it is neither incorporated in Montana nor maintains its principal place of business there. The Montana Supreme Court upheld jurisdiction, finding BNSF’s in-state business activities sufficient for general jurisdiction. The U.S. Supreme Court reversed, holding that Montana courts could not exercise general personal jurisdiction over BNSF because the railroad was not “at home” in the state under the strict standard set in Daimler AG v. Bauman.

The U.S. Supreme Court ruled 8-1 that Montana lacked general personal jurisdiction over BNSF. The judgment of the Montana Supreme Court was reversed and the case remanded for further proceedings consistent with the opinion.

Whether a state court may exercise general personal jurisdiction over a defendant railroad company that is neither incorporated nor has its principal place of business in the forum state, merely on the basis of its in-state business activities.

The decision reinforced Daimler's general jurisdiction framework, significantly curtailing forum shopping by FELA plaintiffs who sought to sue out-of-state railroads in plaintiff-friendly state courts. It clarified that merely doing business in a state does not render a corporation “at home” for general jurisdiction purposes, offering broad protections to national corporations against litigation in forums with no substantial connection to the claim.