Mallory v. Norfolk Southern R. Co
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Mallory v. Norfolk Southern R. Co and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Mallory v. Norfolk Southern R. Co.
The Supreme Court vacated and remanded the Pennsylvania Supreme Court's decision in Mallory v. Norfolk Southern Railway Co. The case involved whether Pennsylvania's law requiring out-of-state companies to consent to personal jurisdiction as a condition of business registration violated the Due Process Clause. The Court found that the law was consistent with precedent set in Pennsylvania Fire Ins. Co. of Philadelphia v. Gold Issue Mining & Milling Co.
Holding
The single most important “bottom line” of what the Court decided in Mallory v. Norfolk Southern R. Co.
The Court held that the Pennsylvania law requiring out-of-state companies to consent to personal jurisdiction does not violate the Due Process Clause.
Constitutional Concepts
These are the Constitution-related themes that appear in Mallory v. Norfolk Southern R. Co. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Mallory v. Norfolk Southern R. Co
The case revolves around whether the exercise of personal jurisdiction by Pennsylvania courts over Norfolk Southern violates the Due Process Clause.
Syllabus excerpt (verbatim)Norfolk Southern—a company incorporated in Virginia and headquartered there—resisted the suit on the basis that a Pennsylvania court's exercise of personal jurisdiction over it would offend the Due Process Clause of the Fourteenth Amendment.
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Why Judicial Review is relevant to Mallory v. Norfolk Southern R. Co
The Court's decision involves reviewing and potentially overturning a state supreme court's interpretation of federal constitutional law.
Syllabus excerpt (verbatim)The Pennsylvania Supreme Court seemed to recognize that Pennsylvania Fire dictated an answer in Mr. Mallory's favor but ruled for Norfolk Southern because, in its view, intervening decisions from this Court had 'implicitly overruled' Pennsylvania Fire.
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Why State–Federal Power is relevant to Mallory v. Norfolk Southern R. Co
The case involves the interaction between state laws requiring business registration and federal constitutional limits on jurisdiction.
Syllabus excerpt (verbatim)Pennsylvania requires out-of-state companies that register to do business in the Commonwealth to agree to appear in its courts on 'any cause of action' against them.
Key Quotes
Short excerpts from the syllabus in Mallory v. Norfolk Southern R. Co that support the summary and concepts above.
The judgment is vacated, and the case remanded.
Pennsylvania Fire held that suits premised on these grounds do not deny a defendant due process of law.
Norfolk Southern has complied with this law since 1998, when it registered to do business in Pennsylvania.
