RESPONDENT: Kelli Tyrell, Special Administrator for the Estate of Brent T. Tyrrell, Deceased, et al.
LOCATION: Supreme Court of Montana
DOCKET NO.: 16-405
LOWER COURT: Montana Supreme Court
CITATION: US ()
GRANTED: Jan 13, 2017
Facts of the case
In March 2011, Robert Nelson was employed by BNSF Railway Co. (BNSF) and sued the company for damages under the Federal Employers’ Liability Act (FELA) based on knee injuries sustained during the course of his employment. BNSF moved to dismiss for lack of personal jurisdiction. The lower court granted the motion and Nelson appealed. Brent Tyrrell also worked for BNSF and was allegedly exposed to carcinogens that caused him to develop ultimately fatal kidney cancer. In May 2014, Kelli Tyrell, the administrator of Brent’s estate, sued BNSF on Brent’s behalf under FELA for damages based on the injuries Brent sustained during the course of his employment. BNSF filed a motion to dismiss Tyrrell’s claim for lack of personal jurisdiction. The lower court denied the motion, and BNSF appealed. Both cases were filed in Montana state court because Supreme Court precedent for FELA decisions allows state courts jurisdiction to hear FELA cases solely due to the railroad doing business in the forum state. However, the injuries did not occur in Montana, and BNSF is incorporated in Delaware with its principal place of business in Texas.
The Supreme Court of Montana consolidated both cases to decide whether Montana courts have personal jurisdiction over BNSF under the FELA and whether Montana courts have personal jurisdiction over BNSF under Montana law. BNSF argued that, under the U.S. Supreme Court’s decision in Daimler AG v. Bauman, the state courts cannot exercising general jurisdiction. However, the Montana Supreme Court rejected that argument and held that, because BNSF does business in Montana, under FELA, Montana courts have personal jurisdiction. Montana’s Supreme Court also held that the state has general personal jurisdiction over BNSF under Montana law because BNSF “maintains substantial, continuous, and systematic” contacts with Montana.
In a suit filed under the Federal Employers’ Liability Act,can a state court decline to follow the U.S. Supreme Court precedent of Daimler AG v. Bauman, which held that a state court cannot exercise personal jurisdiction over a defendant that is not “at home” in the forum state?