Louisville & Nashville Railroad Co. v. Mottley
211 U.S. 149, 29 S. Ct. 42, 53 L. Ed. 126 (1908)
- The Mottleys were a husband and wife who had been injured in a train mishap, and had been compensated with free passes from the railroad company.
- Several decades later, Congress banned free passes in order to prevent their use as bribes, and the railroad then refused to renew the Mottley’s passes.
- The Mottleys sued to enforce their compensation, bringing their case in Federal Court under the theory that the railroad’s refusal to honor the passes was based on an unconstitutional law.
- The Federal Trial Court decided in favor of the Mottleys, the railroad appealed.
- The Federal Appellate Court affirmed. The railroad appealed.
- The US Supreme Court dismissed the case for lack of jurisdiction.
- There was no diversity of citizenship, and no grounds for federal question jurisdiction except that the case ‘arose under federal law’ which is insufficient to satisfy the federal question requirement.
- The case revolved around breach of contract and specific performance. These are State laws. The defense was that there was a Federal law which barred contract. But, the claim here was of State law, only the defense was a question of Federal law.
- The only way a party can get federal question jurisdiction is if the federal question arises in the plaintiff’s well-pleaded complaint.
- A suit arises under Federal law only if the original statement of the plaintiff’s cause of action shows that it is based on the Constitution or Federal statutes.
- This is known as the well-pleaded complaint rule.
- A Federal Court can’t have jurisdiction just because the defendant might use a Federal law or the Constitution to defend himself.
- Following the dismissal of their case, the Mottleys brought a similar action in their State Court. They lost in the State Court, and appealed their loss all the way to the US Supreme Court, where they faced yet another legal defeat.
- Remember, State Courts can decide matters of Federal law.