## Facts

- Douglas, a Connecticut resident employed by a Connecticut-incorporated railroad engaged in interstate commerce, was injured in Connecticut.
- Douglas’s claim arose under the Federal Employers’ Liability Act (FELA).
- Although the injury and parties were connected to Connecticut, the railroad did business in New York and could be served there.
- Douglas sued in a New York state court.
- Under New York law and practice, courts could, in their discretion, decline jurisdiction over suits between nonresidents on causes of action arising outside New York when hearing them would burden local courts and interests.
- The railroad moved to dismiss on the ground that New York courts could refuse such foreign, nonresident-versus-nonresident actions.

## Issues

1. Whether FELA requires a state court to entertain a FELA action arising outside the state between nonresident parties when the defendant is amenable to service in the forum.
2. Whether a state court’s discretionary refusal to exercise jurisdiction over such an action violates the Full Faith and Credit Clause.
3. Whether the refusal denies due process or equal protection under the Fourteenth Amendment.

## Decision

- The U.S. Supreme Court affirmed the dismissal.
- The Court held that FELA permits suit in state courts that have jurisdiction, but does not compel a state to accept every FELA case irrespective of neutral, administratively based limits on entertaining foreign causes of action.
- The Court held that New York’s refusal to provide a forum for this category of case did not violate Full Faith and Credit because it did not deny the validity of FELA; it declined jurisdiction on procedural and administrative grounds.
- The Court held that the practice did not violate due process or equal protection because it was not an arbitrary or hostile discrimination against federal rights and was applied evenhandedly to a class of foreign, nonresident disputes.

## Legal Principles

- A federal statute authorizing suit in state courts does not, without clear command, require every state to entertain every such claim regardless of the state’s neutral rules governing judicial administration.
- A state may decline to hear certain out-of-state causes of action between nonresidents when the refusal rests on bona fide, generally applicable policies concerning court administration and local interests.
- Full Faith and Credit is not violated by a forum’s neutral refusal of jurisdiction where the forum does not reject the substantive validity of the governing law and an adequate alternative forum remains available.
- Equal protection and due process are not violated by jurisdictional classifications grounded in legitimate administrative considerations and not designed to nullify federal rights.

## Conclusion

The Court upheld New York’s discretionary refusal to hear an out-of-state FELA claim between nonresidents, ruling that FELA did not mandate a state forum and that a neutral, non-discriminatory jurisdictional refusal did not offend Full Faith and Credit or the Fourteenth Amendment.


Douglas v. New York, New Haven & Hartford R.R. Co., 279 U.S. 377 (1929)