Louisville & Nashville Railroad Co. v. Mottley
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| Louisville & Nashville Railroad Co. v. Mottley | |||||||||||||
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| Argued October 13, 1908 Decided November 16, 1908 |
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| Holding | |||||||||||||
| A suit arises under the Constitution and laws of the United States only when the plaintiff's statement of his own cause of action shows that it is based upon those laws or that Constitution. | |||||||||||||
| Court membership | |||||||||||||
| Chief Justice: Melville Fuller Associate Justices: John Marshall Harlan, David Josiah Brewer, Edward Douglass White, Rufus Wheeler Peckham, Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day, William Henry Moody |
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| Case opinions | |||||||||||||
| Majority by: Moody Joined by: unanimous |
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| Laws applied | |||||||||||||
| U.S. Const. | |||||||||||||
Louisville & Nashville Railroad Company v. Mottley, 211 U.S. 149 (1908), was a United States Supreme Court decision that held that under the existing statutory scheme, federal question jurisdiction could not be predicated on a plaintiff's anticipation that the defendant would raise a federal statute as a defense. Instead, such jurisdiction can only arise from a complaint by the plaintiff that the defendant has directly violated some provision of the Constitution, laws, or treaties of the United States.
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[edit] Facts
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, in 1906, the U.S. 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 lower federal courts decided in favor of the Mottleys, and the railroad appealed to the U.S. Supreme Court.
[edit] Issue
The Supreme Court, sua sponte, questioned the existence of subject matter jurisdiction, transforming the issue into whether this was a case that could have been brought in federal court in the first place.
[edit] Opinion of the Court
The Supreme Court, in an opinion by Justice Moody, 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 only way a party can get federal question jurisdiction is if the federal question arises in the plaintiff's well-pleaded complaint.
[edit] Later developments
Following the dismissal of their case, the Mottleys brought a similar action in Kentucky state court. The state court held for them, and ordered the railroad to issue the passes. The railroad appealed to the Court of Appeals of Kentucky and lost. The railroad appealed again to the U.S. Supreme Court, which ruled in favor of the railroad, thereby handing the Mottleys yet another legal defeat.
