In BNSF Railway Co. v. Tyrrell, 137 S. Ct. 1549 (U.S. 2017) (No. 16-405), plaintiff employees sued the defendant railroad under the Federal Employers’ Liability Act (FELA) in Montana state court. The defendant was neither headquartered nor incorporated in Montana, but it did operate more than 2,000 miles of railroad track and employ more than 2,000 workers in Montana. The Montana Supreme Court held that Montana courts could exercise general personal jurisdiction over defendant, ruling that jurisdiction was conferred under either FELA (which authorized suit to be brought in a federal court in the district where “the defendant shall be doing business”), or alternatively, under Montana law, which provides for the exercise of personal jurisdiction over “all persons found within” the State. The US Supreme Court reversed. The Court ruled that the provisions of FELA relied upon by plaintiffs merely established venue for a federal-court action; they did not confer personal jurisdiction on any court. The Court further determined that the Montana courts’ exercise of personal jurisdiction under Montana law violated the Due Process Clause of the Fourteenth Amendment. Citing to its earlier ruling in Daimler AG v. Bauman, 134 S. Ct. 746 (U.S. 2014), the Court reiterated that a court may assert general jurisdiction over a foreign corporation only when its affiliations with the State are so continuous and systematic as to render them essentially at home in the forum State; and other than in “exceptional case[s],” that is generally limited to its place of incorporation and its principal place of business. The Court rejected the argument that this jurisdictional test should not apply to a FELA claim or a railroad defendant, and clarified that this rule applies to all state-court assertions of general jurisdiction over nonresident defendants, and does not vary with the type of claim asserted or business enterprise sued.