McKnett v. St. Louis & San Francisco Railway Co.

Supreme Court of the United States · 1934 · Federal Courts

Federal CourtsFederal Employers' Liability Actstate court jurisdictiondiscrimination against federal rightsgeneral jurisdictionSupremacy Clausetransitory actions

Facts

McKnett, a Tennessee resident, sued the St. Louis & San Francisco Railway Company, a foreign corporation doing business in Alabama, in an Alabama circuit court under the Federal Employers' Liability Act for an injury suffered in Tennessee. The railway argued that Alabama lacked jurisdiction because the cause of action arose wholly in Tennessee and did not arise by the common law or statute of Tennessee within the meaning of Alabama Code § 5681. Alabama's highest court agreed, construing the statute to cover only causes of action arising under the law of another state, not under federal law. Alabama otherwise gave its circuit courts general jurisdiction over this class of actions in comparable cases.

Issue

May a state court of general jurisdiction refuse to entertain a Federal Employers' Liability Act suit when its ordinary jurisdiction is adequate, solely because the cause of action arises under federal law rather than under state law? More specifically, may Alabama deny jurisdiction on the ground that its statute covers only causes arising under another state's law and not under a federal statute?

Rule

Although a state may generally define the jurisdiction of its courts, the Federal Constitution forbids a state court of general jurisdiction from refusing to entertain a cause of action solely because it arises under federal law, where the court's ordinary jurisdiction as prescribed by local law is otherwise appropriate to enforce that right.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Lena Ortiz, a resident of New Mexico, sues Red Mesa Freight Lines, a Colorado corporation doing business in Arizona, in an Arizona trial court under a federal railroad injury statute for an accident in Utah. Arizona courts regularly hear comparable personal-injury suits against out-of-state corporations when the claim arises under Arizona law or Utah law, but an Arizona statute has been construed to exclude claims arising under federal law.

If the Arizona court dismisses solely because Lena's claim arises under federal law, which is the best answer?

Explanation. When a state court's ordinary jurisdiction is otherwise appropriate for the class of action and the defendant, the Federal Constitution forbids the state from denying jurisdiction solely because the cause of action arises under federal law. The problem is discrimination based on the source of law, not the plaintiff's residence or the out-of-state location of the injury. (Derived from McKnett v. St. Louis & San Francisco Railway Co. (1934).)