It seems like it happens every spring: Once again, the U.S. Supreme Court has reversed a state court’s expansive view of personal jurisdiction. In BNSF Railway Co. v. Tyrrell, the Supreme Court reversed the Montana Supreme Court’s ruling that state courts may exercise general personal jurisdiction over out-of-state defendants when adjudicating claims under the Federal Employers’ Liability Act (FELA).

In an 8-1 decision authored by Justice Ruth Bader Ginsburg, the Supreme Court held that (1) FELA did not address the personal jurisdiction of state courts, and (2) the U.S. Constitution’s due process guarantees prohibited Montana courts from exercising general personal jurisdiction over the defendant in that case. As we discussed (and predicted) in recent articles, yesterday’s decision in BNSF Railway is the latest in a series of recent efforts by the Supreme Court to curtail state court expansion of personal jurisdiction over nonresident defendants.

Originally published in Law360 on June 1, 2017.