# What is the significance of the BNSF R.

CO.

v.

TYRRELL case?

legalpdf.io · August 4, 2026

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The BNSF R.

CO.

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v.

TYRRELL case overturned a previous Montana Supreme Court ruling that had allowed the case to be heard in Montana courts, even though BNSF Railway was not headquartered or incorporated in Montana.

The Supreme Court's ruling emphasized that the appropriate test for jurisdiction under the Federal Employers' Liability Act (FELA) is the "at home" standard established in the Daimler v.

Bauman decision, which limits when a corporation can be sued in a state where it is not incorporated or headquartered.

The Court's decision in BNSF R.

CO.

v.

TYRRELL significantly restricted where employees can file FELA lawsuits against railroads, limiting it to the states where the railroad is "at home."

Prior to this ruling, some state courts had adopted a more permissive approach to personal jurisdiction, allowing FELA cases to be brought wherever the railroad did substantial business, even if it was not headquartered or incorporated there.

The BNSF R.

CO.

v.

TYRRELL case reinforced the Supreme Court's trend of limiting the reach of general personal jurisdiction over corporations, following the Daimler decision.

The decision was unanimous, with all nine justices agreeing that Montana lacked personal jurisdiction over BNSF in this case under the FELA statute.

The Court's ruling in BNSF R.

CO.

v.

TYRRELL was seen as a victory for businesses, as it made it more difficult for plaintiffs to forum shop and file suits in states with more favorable laws.

The case highlighted the ongoing tension between the Due Process Clause and the FELA statute's provision allowing state courts concurrent jurisdiction over FELA claims.

BNSF R.

CO.

v.

TYRRELL was the first Supreme Court case to directly address the scope of personal jurisdiction under FELA since the Daimler decision.

The ruling in BNSF R.

CO.

v.

TYRRELL is likely to have significant implications for other federal statutes that provide for concurrent state court jurisdiction, such as the Jones Act for maritime workers.

The decision reinforced the Supreme Court's preference for a more rigid, predictable framework for determining personal jurisdiction, rather than a more flexible "minimum contacts" analysis.

BNSF R.

CO.

v.

TYRRELL was seen as a departure from the Court's earlier decision in Goodyear Dunlop Tires Operations, S.A.

v.

Brown, which had suggested a more expansive view of general jurisdiction.

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