Knett v. St Louis Co

Decision Date30 April 1934
Docket NumberS.F. RY,No. 597,597
Citation54 S.Ct. 690,78 L.Ed. 1227,292 U.S. 230
PartiesMcKNETT v. ST. LOUIS &CO. *
CourtU.S. Supreme Court

Messrs. J. K. Jackson and Walter Brower, both of Birmingham, Ala., for petitioner.

Mr. L. D. Gardner, Jr., of Birmingham, Ala., for respondent.

Mr. Justice BRANDEIS delivered the opinion of the Court.

This action was brought under the Federal Employers' Liability Act (45 USCA §§ 51—59), in the circuit court of Jefferson county, Ala., to recover damages for an injury suffered in Tennessee. The plaintiff, McKnett, is a resident of Tennessee. The defendant, St. Louis & San Francisco Railway Company, is a foreign corporation doing business in Alabama. It pleaded in abatement that the court lacked jurisdiction, since the cause of action had arisen wholly in Tennessee and did not arise by the common law or statute of that state. The plea rested upon the limiting words of the act of 1907, now embodied in section 5681, Code 1923, which declares: 'Whenever, either by common law or the statutes of another state, a cause of action, either upon contract, or in tort, has arisen in such other state against any person or corporation, such cause of action shall be enforceable in the courts of this state, in any county in which jurisdiction of the defendant can be legally obtained in the same manner in which jurisdiction could have been obtained if the cause of action had arisen in this state.'

A demurrer to the plea was overruled; and the judgment entered thereon for the defendant was affirmed by the highest court of the State. 227 Ala. 349, 149 So. 822. This Court granted certiorari, 290 U.S. 621, 54 S.Ct. 210, 78 L.Ed. —-.

The courts of Alabama have, at all times, taken jurisdiction of suits between natural persons on transitory causes of action arising in another state, even if both of the parties were nonresidents of Alabama.1 But prior to the act of 1907, it had been consistently held, under the rule established by Central Railroad & Banking Company v. Carr, 76 Ala. 388, 52 Am.Rep. 339, that no Alabama court had jurisdiction of any suit against a foreign corporation unless the cause of action had arisen within the state.2 In the case at bar the court held that, despite the 1907 act, lack of jurisdiction still existed in respect to causes of action arising in another state under the federal law; because, since the statute was in plain terms limited to suits arising under the law of the other state, it could not be extended by construction to include causes of action arising in such other state under a federal law.

The plaintiff contends that by refusing to entertain jurisdiction, the state court has denied him a right expressly conferred by Congress and guaranteed by the Federal Constitution. The defendant insists that the statute as construed is consistent with the Federal Constitution; since a state may determine the limits of the jurisdiction of its courts, the character of the controversies which shall be heard in them, Anglo-American Provision Company, v. Davis Provision Co., No. 1, 191 U.S. 373, 24 S.Ct. 92, 48 L.Ed. 225; Chambers v. Baltimore & Ohio R.R. Co., 207 U.S. 142, 148, 149, 28 S.Ct. 34, 52 L.Ed. 143; and the extent to which its courts shall become a forum for the trial of transitory causes of action arising in other states, Missouri Pacific R.R. Co. v. Clarendon Boat Oar Co., 257 U.S. 533, 42 S.Ct. 210, 66 L.Ed. 354; Douglas v. New York, New Haven & Hartford R.R. Co., 279 U.S. 377, 49 S.Ct. 355, 73 L.Ed. 747.

Alabama has granted to its circuit courts general jurisdiction of the class of actions to which that here brought belongs, in cases between litigants situated like those in the case at bar.3 The court would have had jurisdiction of the cause between these parties if the accident had occurred in Alabama. It would have had jurisdiction although the accident occurred in Tennessee, if the defendant had been a domestic corporation. It would have had jurisdiction, although the defendant was a foreign corporation, the plaintiff a nonresident, and the accident occurred in Tennessee, if the suit had been brought for an injury suffered while engaged in intrastate commerce. Thus, the ordinary jurisdiction of the Alabama circuit court is appropriate to enforce the right against this defendant conferred upon the plaintiff by the Federal Employers' Liability Act. And its jurisdiction was invoked according to the rules of procedure prevailing in that court.

The power of a state to determine the limits of the jurisdiction of its courts and the character of the controversies which shall be heard in them is, of course, subject to the restrictions imposed by the Federal Constitution. The privileges and immunities clause (article 4, § 2, cl. 1) requires a state to accord to citizens of other states substantially the same right of access to its courts as it accords to its own citizens. Corfield v. Coryell, Fed. Cas. No. 3,230, 4 Wash.C.C. 371, 381. Compare Canadian Northern Ry. Co. v. Eggen, 252 U.S. 553, 40 S.Ct. 402, 64 L.Ed. 713. The full faith and credit clause (article 4, § 1) requires a state court to take jurisdiction of an action to enforce a judgment recovered in another state, although it might have refused to entertain a suit on the original cause of action as obnoxious to its public policy. Fauntleroy v. Lum, 210 U.S. 230, 28 S.Ct. 641, 52 L.Ed. 1039; Kenney v. Supreme Lodge, 252 U.S. 411, 415, 40 S.Ct. 371, 64 L.Ed. 638, 10 A.L.R. 716; ...

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116 cases
  • Schultz v. Union Pac. R. Co.
    • United States
    • California Court of Appeals Court of Appeals
    • 27 Mayo 1953
    ...State for reasons of local policy denies resort to its courts and enforces its policy impartially, see McKnett v. St. Louis & S. F. R. Co., 292 U.S. 230, 54 S.Ct. 690, 78 L.Ed. 1227, so as not to involve a discrimination against Employers' Liability Act suits and not to offend against the P......
  • Matthewman v. Akahane
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    • U.S. District Court — District of Hawaii
    • 15 Noviembre 1983
    ...a theme that is consistently repeated by the U.S. Supreme Court, albeit mostly in dicta. See, McKnett v. St. Louis & S.F.R. Co., 292 U.S. 230, 234, 54 S.Ct. 690, 692, 78 L.Ed. 1227, 1229 (1934); Miles v. Illinois C.R. Co., 315 U.S. 698, 704, 62 S.Ct. 827, 830, 86 L.Ed. 1129, 1134, 146 A.L.R......
  • Wong v. Restoration Robotics, Inc.
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    • California Court of Appeals Court of Appeals
    • 28 Abril 2022
    ...the Supremacy Clause, "[a] state may not discriminate against rights arising under federal laws." ( McKnett v. St. Louis & S.F. Ry. Co. (1934) 292 U.S. 230, 234, 54 S.Ct. 690, 78 L.Ed. 1227.) The Supremacy Clause prohibits states from "dissociat[ing] themselves from federal law because of d......
  • Miles v. Illinois Cent Co
    • United States
    • U.S. Supreme Court
    • 30 Marzo 1942
    ...to its own citizens, violate the Privileges and Immunities Clause. Constitution, Art. IV, § 2; McKnett v. St. Louis & S.F. Ry. Co., 292 U.S. 230, 233, 54 S.Ct. 690, 691, 78 L.Ed. 1227.6 Since the existence of the cause of action and the privilege of vindicating rights under the F.E.L.A. in ......
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1 books & journal articles
  • Medical Malpractice as Workers' Comp: Overcoming State Constitutional Barriers to Tort Reform
    • United States
    • Emory University School of Law Emory Law Journal No. 67-5, 2018
    • Invalid date
    ...Rev. 1309 (2003).167. See infra Section IV.A.168. See, e.g., Bounds v. Smith, 430 U.S. 817, 821 (1977); McKnett v. St. Louis & S.F. Ry., 292 U.S. 230, 233 (1934); Chambers v. Balt. & Ohio R.R., 207 U.S. 142, 148 (1907).169. See, e.g., State v. Moseley, 436 S.E.2d 632, 634 (Ga. 1993) (declin......

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