U.S. Supreme Court
Southern Railway Co. v. Mayfield, 340 U.S. 1 (1950)
Southern Railway Co. v. Mayfield
Argued October 16, 1950
Decided November 6, 1950
340 U.S. 1
In each of two suits brought in a Missouri state court under the Federal Employers' Liability Act, the plaintiff was not a resident of Missouri, the carrier was a foreign corporation, and the accident which gave rise to the claim occurred outside of Missouri. The State Supreme Court determined that the doctrine of forum non conveniens could not bar the suits; but it was not clear whether this holding was based on local law or upon a belief that it was required by federal law as enunciated by this Court.
Held: the judgment is vacated, and the cause is remanded, in order that the State Supreme Court may determine the availability of the principle of forum non conveniens according to its own local law. Pp. 340 U. S. 2-3, 340 U. S. 5.
(a) Neither Baltimore & O. R. Co. v. Kepner, 314 U. S. 44, nor Miles v. Illinois Central R. Co., 315 U. S. 698, limited the power of a state to deny access to its courts to persons seeking recovery under the Federal Employers' Liability Act if, in similar cases, the state, for reasons of local policy, denies resort to its courts and enforces its policy impartially, so as not to involve a discrimination against Employers' Liability Act suits nor against citizens of other states. P. 340 U. S. 4.
(b) Nor is any such restriction imposed upon the states merely because the Employers' Liability Act empowers their courts to entertain suits arising under it. P. 340 U. S. 4. chanroblesvirtualawlibrary
(c) Even prior to § 1404(a) of the 1948 revision of the Judicial Code (28 U.S.C.), there was nothing in the Federal Employers' Liability Act which purported "to force a duty" upon the state courts to entertain or retain Federal Employers' Liability litigation "against an otherwise valid excuse." Pp. 340 U. S. 5.
359 Mo. 827, 224 S.W.2d 105, judgment vacated and cause remanded.
In two suits brought in a Missouri state court under the Federal Employers' Liability Act, motions to dismiss under the doctrine of forum non conveniens were denied as beyond the jurisdiction of the court to grant. In original proceedings in mandamus to compel the trial court to exercise discretionary jurisdiction in disposing of the motions, the State Supreme Court denied relief. 359 Mo. 827, 224 S.W.2d 105. This Court granted certiorari. 339 U.S. 918. Judgment vacated and cause remanded, p. 340 U. S. 5.