Louisville & Nashville Railroad Co. v. Mottley

SCOTUSCase
Litigants=Louisville & Nashville Railroad Co. v. Mottley
ArgueDate=October 13
ArgueYear=1908
DecideDate=November 16
DecideYear=1908
FullName=Louisville & Nashville Railroad Company v. E. L. Mottley and Annie E. Mottley
USVol=211
USPage=149
Citation=29 S. Ct. 42; 53 L. Ed. 126; 1908 U.S. LEXIS 1533
Prior=Appeal from the Circuit Court of the United States for the Western District of Kentucky
Subsequent=
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.
SCOTUS=1906-1909
Majority=Moody
JoinMajority="unanimous"
LawsApplied=U.S. Const.

"Louisville & Nashville Railroad Company v. Mottley", 211 U.S. 149 (1908)ref|citation, 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.

Facts

The Mottleys were a husband and wife who had been injured in a train mishap. In exchange for agreeing not to hold the Railroad liable, they were compensated with free passes from the Louisville and Nashville Railroad company, which were to be renewed annually. 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 for specific performance of the rail passes, bringing their case in federal court. They argued that either the congressional statute did not apply because they had been issued the passes decades before the law went into effect, or if the law did apply, that it was unconstitutional because it deprived them of their property (the passes). The lower federal courts decided in favor of the Mottleys, and the railroad appealed to the U.S. Supreme Court.

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.

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.

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 ("Louisville & N. R. Co. v. Mottley", 219 U.S. 467 (1911))ref|citation, thereby handing the Mottleys yet another legal defeat.

ee also

* List of United States Supreme Court cases, volume 211

External links

*ussc|211|149|Text of the opinion on Findlaw.com
*ussc|219|467|Text of the opinion on Findlaw.com