## Facts

- Eggen, a U.S. citizen residing in a state neighboring Minnesota, worked as a switchman for Canadian Northern Railway in Saskatchewan, Canada.
- Eggen was injured on November 29, 1913, while working in the railway’s yards in Humboldt, Saskatchewan.
- Eggen remained in Canada for about six months after the accident, then returned to live in the neighboring state.
- Eggen sued the railway in the U.S. District Court for the District of Minnesota on October 15, 1915, nearly two years after the injury.
- Canadian law where the injury occurred required personal-injury actions to be brought within one year; by the time Eggen sued in Minnesota, the claim was barred in Canada.
- Minnesota had a general six-year limitations period, but also a borrowing statute providing that when a cause of action arises outside Minnesota and is time-barred where it arose, it cannot be maintained in Minnesota unless the plaintiff is a Minnesota citizen who has owned the claim continuously since it accrued.
- Because Eggen was not a Minnesota citizen and the claim was barred in Canada, the borrowing statute barred the suit.

## Issues

1. Whether Minnesota’s borrowing statute, which permits only Minnesota citizens to sue on out-of-state claims already time-barred where they arose, violates the Privileges and Immunities Clause by discriminating against nonresident citizens.

## Decision

- The Supreme Court reversed the court of appeals and upheld the Minnesota borrowing statute as constitutional.
- The Court held that the Privileges and Immunities Clause protects nonresidents’ fundamental right to access another state’s courts, but does not require identical procedural advantages for residents and nonresidents.
- The Court concluded Minnesota could reasonably deny nonresidents the ability to revive claims already barred in the jurisdiction of accrual, while granting limited protection to its own citizens.
- Eggen’s suit was barred in Minnesota because the claim was time-barred in Canada and he did not fall within the Minnesota-citizen exception.

## Legal Principles

- The Privileges and Immunities Clause protects a nonresident citizen’s right to institute and maintain actions in another state’s courts as a fundamental privilege.
- A state satisfies the clause if nonresidents have access to its courts on terms that are “reasonable and adequate” to enforce whatever rights they have, even if the terms differ from those given to resident citizens.
- States may apply borrowing statutes to prevent forum shopping and to avoid reopening claims already time-barred where they arose.
- A state may make reasonable legislative classifications favoring its own citizens in determining whether to allow litigation of foreign claims that are already barred at the place of accrual.

## Conclusion

Minnesota’s borrowing statute constitutionally barred a nonresident’s suit on a Canadian personal-injury claim that was already time-barred in Canada; the statute’s exception for Minnesota citizens did not violate the Privileges and Immunities Clause because nonresidents retained reasonable and adequate court access for claims not barred where they arose.


Canadian N. Ry. Co. v. Eggen, 252 U.S. 553 (1920)