Injured Railroad Workers Cannot Sue Railroad in State Where Injury Did Not Occur and Where They Do Not Live
The U.S. Supreme Court ruled earlier today that the Montana Supreme Court incorrectly asserted personal jurisdiction over a railroad in two cases regarding on-the-job injuries. Even though both suits were pursued in Montana state courts, neither of the injured workers resided in Montana and neither were injured in Montana. Montana’s Supreme Court predicated its finding of personal jurisdiction under the Federal Employers’ Liability Act (FELA), which makes railroads responsible for money damages to their employees for on-the-job-injuries, and Montana’s personal jurisdiction rules.
The case originated in March 2011 when a North Dakota resident brought a FELA suit against the railroad company seeking damages for leg injuries sustained in the course of his employment. In 2014, a South Dakota resident brought a similar case as the administrator of her husband’s estate, alleging that her husband had developed kidney cancer and died from exposure to carcinogenic chemicals while working for the same company. Neither plaintiff alleged the respective injuries occurred in Montana and neither plaintiff appeared to have ever worked for the companies in Montana, yet both suits were filed in Montana.
The Montana Supreme Court consolidated the cases and held that Montana state courts could exercise personal jurisdiction over the railroad company. The court claimed general jurisdiction over the out-of-state corporation by citing the more than 2,000 miles of rail and 2,000 employees in Montana, which met its definition of “continuous and systematic” contacts “as to render [the company] essentially at home.”
The U.S. Supreme Court overruled the Montana decision, ruling that state courts cannot assert jurisdiction over claims made by nonresident employees working outside the state. The Court concluded 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.”
The Montana Supreme Court’s ruling also relied on 45 U.S.C. § 56 to justify its exercise of personal jurisdiction under the FELA, which provides, “Under this chapter an action may be brought in a district court of the United States, in the district of the residence of the defendant, or in which the cause of action arose, or in which the defendant shall be doing business at the time of commencing such action. The jurisdiction of the courts of the United States under this chapter shall be concurrent with that of the courts of the several States.” The Court held that this section does not address personal jurisdiction over railroads, and instead it relates to a venue prescription and clarifies that federal courts do not have exclusive subject-matter jurisdiction over FELA suits.
Justice Ginsburg wrote the Opinion for the Majority. The case number is 16-405 in the U.S. Supreme Court. Justice Sotomayor filed an opinion concurring in part and dissenting in part. As she previously made clear in her concurring opinion in Daimler AG v. Bauman, 571 U.S. __ (2014), she continues to disagree with the path the Court struck in Daimler that limits general jurisdiction over a corporate defendant to only those States where it is “essentially at home.”
