Personal Jurisdiction—Constitutional Limits of General Jurisdiction

BNSF Railway Co. v. Tyrrell, No. 16-405

Under the Supreme Court’s ruling in Daimler AG v. Bauman, 134 S. Ct. 746 (2014), a state court may only exercise general personal jurisdiction over a defendant that is “at home” in the forum state. In a case arising under the Federal Employers’ Liability Act, the Supreme Court of Montana held that Montana state courts had general jurisdiction over a defendant that was incorporated and had its principal place of business out of state. The Montana Supreme Court declined to apply the holding of Daimler, which involved overseas parties and transnational injuries, to cases involving U.S. defendants and domestic conduct. The Supreme Court has granted certiorari to clarify the scope of its decision in Daimler with respect to U.S. corporations.