Supreme Court limits reach of U.S. courts
Term’s first ruling says woman can’t sue for accident in Austria
The Supreme Court limited the international reach of U.S. courts Tuesday, refusing to let a California woman who lost her legs in an Austrian national railway accident sue for damages nearly 6,000 miles away in San Francisco.
The 9-0 ruling, written by Chief Justice John Roberts, was the first of the high court’s 2015 term.
The woman, Carol Sachs, fell off a train platform in Innsbruck in 2007 and needed both her legs amputated above the knee. Because she had purchased her four-day Eurail pass from a Massachusetts-based travel agency, she sued in federal district court in California rather than navigating Austria’s legal system.
The district court ruled against her, reasoning that the injury did not have a sufficient connection to the USA. A federal appeals court reversed and said the railway could be liable for the sale of the Eurail pass, along with any defects in its platform or loading protocol.
The key to the case: whether Sachs’ claim was “based upon” her ticket purchase and whether the travel agency could be considered an agent of the Austrian railway. During oral arguments in October, the justices expressed doubt that U.S. courts were the place to file suit, and Roberts confirmed those doubts Tuesday.
“There was nothing wrongful about the sale of the pass standing alone,” the chief justice said from the bench. Rather, “what happened in Austria” represented the heart of the case, and therefore any lawsuit should have been brought there.
“All of her claims turn on the same trag- ic episode in Austria, allegedly caused by wrongful conduct and dangerous conditions in Austria, which led to injuries in Austria,” Roberts wrote.
Basing his opinion on a high court ruling in 1993 that granted Saudi Arabia immunity from a U.S.-based lawsuit, Roberts also drew from a letter by Justice Oliver Wendell Holmes to Felix Frankfurter, who later would join the court. In it, Holmes wrote that the key to a personal injury case is the point of contact — “the place where the boy got his fingers pinched.”
“At least in this case, that insight holds true,” Roberts said.
Stanford University law professor Jeffrey Fisher, who represented Sachs, warned that protecting the Austrian railway from lawsuits in U.S. courts could have broad consequences for other types of lawsuits against foreign governments. Modern transportation contracts have clauses stipulating where lawsuits can and cannot be filed, he said, “so you’ll never see this kind of case again.”
The case hinged on the court’s interpretation of the Foreign Sovereign Immunities Act, a 1976 law passed by Congress that limits the reach of U.S. courts. Foreign companies have no such immunity, but the justices ruled last year that even companies can sidestep U.S. lawsuits if their actions took place entirely outside the country.