Louisville & Nashville R. Co. v. Mottley, 211 U.S. 149 (1908)
To determine whether federal question jurisdiction is appropriate, a court should consider only the complaint, rather than any anticipated defenses or any counterclaims or cross-claims.
The Louisville & Nashville Railroad Company gave the Mottleys lifetime passes in exchange for waiving their damages claims that arose from an accident when they were traveling on the railroad. However, Congress later passed a law that prohibited companies from providing free passes or free transportation, so the railroad refused to renew the passes. The Mottleys brought a claim in federal court in Kentucky, which was the home state for both the railroad and them. They argued that the law did not prevent the railroad from issuing a lifetime pass in this particular situation, and if it did it would violate the Fifth Amendment. The Mottleys prevailed in the trial court.Opinions
- William Henry Moody (Author)
- Melville Weston Fuller
- John Marshall Harlan
- David Josiah Brewer
- Edward Douglass White
- Rufus Wheeler Peckham
- William Rufus Day
- Joseph McKenna
- Oliver Wendell Holmes, Jr.
There was no diversity of citizenship and no connection between the original cause of action and either the Constitution or federal laws. Jurisdiction could not be found because the Constitution might be used to invalidate an anticipated defense. A federal question that forms the basis of jurisdiction must be found in the original cause of action. The court did not have jurisdiction over the case, so it should be dismissed.Case Commentary
Federal question jurisdiction arises only if the plaintiff pleads facts in the complaint that give rise to it. The well-pleaded complaint rule thus limits the jurisdiction of federal courts. Interestingly, the Mottleys prevailed again when they brought a claim in state court, but the U.S. Supreme Court again reversed, this time on the merits.
U.S. Supreme CourtLouisville & Nashville R. Co. v. Mottley, 211 U.S. 149 (1908)
Louisville and Nashville Railroad Company v. Mottley
Argued October 13, 1908
Decided November 16, 1908
211 U.S. 149
The jurisdiction of the circuit court is defined and limited by statute; and, even if not questioned by either party, this Court will, of its own motion, see to it that such jurisdiction is not exceeded.
A suit arises under the Constitution and laws of the United States, so as to give the circuit court jurisdiction on that ground, only when plaintiff's statement of his own cause is based thereon; that jurisdiction cannot be based on an alleged anticipated defense which may
be set up and which is invalid under some law or provision of the Constitution of the United States.
The circuit court has no jurisdiction, in the absence of diverse citizenship, of a suit brought against a railroad corporation to enforce an alleged contract for an annual pass because, as stated in the bill, the refusal is based solely on the anti-pass provisions of the Hepburn Interstate Commerce Act of June 29, 1906, c. 3591, 34 Stat. 584.
The practice in such cases is to reverse the judgment and remit the case to the Circuit Court with instructions to dismiss the suit for want of jurisdiction.
The appellees (husband and wife), being residents and citizens of Kentucky, brought this suit in equity in the Circuit Court of the United States for the Western District of Kentucky against the appellant, a railroad company and a citizen of the same state. The object of the suit was to compel the specific performance of the following contract:
"Louisville, Ky., Oct. 2nd 1871"
"The Louisville & Nashville Railroad Company, in consideration that E. L. Mottley and wife, Annie E. Mottley, have this day released company from all damages or claims for damages for injuries received by them on the 7th of September, 1871, in consequence of a collision of trains on the railroad of said company at Randolph's Station, Jefferson County, Kentucky, hereby agrees to issue free passes on said railroad and branches now existing or to exist, to said E. L. & Annie E. Mottley for the remainder of the present year, and thereafter to renew said passes annually during the lives of said Mottley and wife or either of them."
The bill alleged that, in September, 1871, plaintiffs, while passengers upon the defendant railroad, were injured by the defendant's negligence, and released their respective claims for damages in consideration of the agreement for transportation during their lives, expressed in the contract. It is alleged that the contract was performed by the defendant up to January 1, 1907, when the defendant declined to renew the passes. The bill then alleges that the refusal to comply with the contract
was based solely upon that part of the Act of Congress of June 29, 1906, 34 Stat. 584, c. 3591, which forbids the giving of free passes or free transportation. The bill further alleges: first, that the act of Congress referred to does not prohibit the giving of passes under the circumstances of this case, and second, that, if the law is to be construed as prohibiting such passes, it is in conflict with the Fifth Amendment of the Constitution, because it deprives the plaintiffs of their property without due process of law. The defendant demurred to the bill. The judge of the circuit court overruled the demurrer, entered a decree for the relief prayed for, and the defendant appealed directly to this Court.