Civil Procedure / Civil Procedure / Subject Matter Jurisdiction

Louisville & Nashville R.R. v. Mottley, 211 U.S. 149 (1908)
Nov 01, 2017 by Stealthy Joe

Facts and Procedural History

Mottleys were injured while passengers on the Louisville & Nashville RR. They settled the claim and received free lifetime passes on the RR. However, decades later, Congress passed a law that banned free passes on railroads, and the RR therefore did not renew the pass. Mottleys (P) sue for specific performance of the contract, win in circuit court, but then the defendant appeals the case in federal court


If the plaintiff's complaint does not allege a federal question, but federal law addresses a possible defense from defendant, is that sufficient to create federal question SMJ?

Holding and Dissent(s)

No, the federal court does NOT have SMJ (subject-matter jurisdiction) because the case "merely arose" under federal law, and was insufficient to create federal question jurisdiction. The "well-pleaded" complaint rule holds that the federal question must appear in the properly pleaded allegations in the complaint. Here, the complaint only alleges breach of contract, which is a state claim.

Analysis and Discussion

Anticipation of defense that is based on federal law (or federal counterclaim) is insufficient to create federal question jurisdiction. Well-pleaded complaint does not apply to cases appealed from state courts to the US Supreme Court, however.

"...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. It is not enough that the plaintiff alleges some anticipated defense to his cause of action, and asserts that the defense is invalidated by some provision of the Constitution of the United States."

Note: A violation of a a federal statute does not necessarily create a federal cause of action, unless the statute also provides a remedy for the violation. A plaintiff's state law-based complaint that is substantially impacted by federal law may also similarly create federal jurisdiction.

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