''Louisville & Nashville Railroad Company v. Mottley'', 211 U.S. 149 (1908), was a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

decision that held that under the existing statutory scheme,

federal question jurisdiction In United States law, federal question jurisdiction is a type of subject-matter jurisdiction that gives United States federal courts the power to hear civil cases where the plaintiff alleges a violation of the United States Constitution, federa ...

could not be predicated on a

plaintiff A plaintiff ( Π in legal shorthand) is the party who initiates a lawsuit (also known as an ''action'') before a court. By doing so, the plaintiff seeks a legal remedy. If this search is successful, the court will issue judgment in favor of the p ...

's anticipation that the

defendant In court proceedings, a defendant is a person or object who is the party either accused of committing a crime in criminal prosecution or against whom some type of civil relief is being sought in a civil case. Terminology varies from one jurisdic ...

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 A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of Legal entity, entity and commonly determine how that entity is to be governed. When ...

, laws, or treaties of the

United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country primarily located in North America. It consists of 50 states, a federal district, five major unincorporated territorie ...

. This reading of the federal question jurisdiction statute is now known as the well-pleaded complaint rule.

Facts

The Mottleys, Erasmus and Annie, were a husband and wife who had been injured in a

train wreck A train wreck, train collision, train accident or train crash is a type of disaster involving one or more trains. Train wrecks often occur as a result of miscommunication, as when a moving train meets another train on the same track; or an acci ...

on September 7, 1871, in

Jefferson County, Kentucky Jefferson County is located in the north central portion of the U.S. state of Kentucky. As of the 2020 census, the population was 782,969. It is the most populous county in the commonwealth (with more than twice the population of second ranked ...

. In exchange for releasing the railroad from liability, they were compensated with free passes from the

Louisville and Nashville Railroad The Louisville and Nashville Railroad , commonly called the L&N, was a Class I railroad that operated freight and passenger services in the southeast United States. Chartered by the Commonwealth of Kentucky in 1850, the road grew into one of the ...

company, which were to be renewed annually. Several decades later, in the

Hepburn Act The Hepburn Act is a 1906 United States federal law that expanded the jurisdiction of the Interstate Commerce Commission (ICC) and gave it the power to set maximum railroad rates. This led to the discontinuation of free passes to loyal shippers. ...

(1906), the

U.S. Congress The United States Congress is the legislature of the federal government of the United States. It is Bicameralism, bicameral, composed of a lower body, the United States House of Representatives, House of Representatives, and an upper body, ...

banned certain types of free passes starting from January 1, 1907 in order to prevent them from being used to

bribe Bribery is the offering, giving, receiving, or soliciting of any item of value to influence the actions of an official, or other person, in charge of a public or legal duty. With regard to governmental operations, essentially, bribery is "Corr ...

government officials, and the railroad refused to renew the Mottleys' passes in 1907. The Mottleys sued for

specific performance Specific performance is an equitable remedy in the law of contract, whereby a court issues an order requiring a party to perform a specific act, such as to complete performance of the contract. It is typically available in the sale of land law, ...

of the rail passes in federal court. They argued that either the federal 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 In law, ''sua sponte'' (Latin: "of his, her, its or their own accord") or ''suo motu'' ("on its own motion") describes an act of authority taken without formal prompting from another party. The term is usually applied to actions by a judge taken wi ...

'', questioned the existence of

subject matter jurisdiction Subject-matter jurisdiction (also called jurisdiction ''ratione materiae')'' is the authority of a court to hear cases of a particular type or cases relating to a specific subject matter. For instance, bankruptcy court only has the authority ...

, 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

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. It is important to note that this holding was an interpretation of jurisdictional statutes rather than of the Constitution's Article III. That is, "arising under" for Article III purposes is broader than the well-pleaded complaint rule. It is well-established that Congress may grant lower federal courts less than the totality of Article III's possible federal question jurisdiction; for example, before 1980, federal question jurisdiction had an amount in controversy requirement, similar to the requirement that still exists in diversity cases. By analogy, jurisdiction premised on diversity of citizenship in Article III is broader than the modern "total diversity" requirement under the jurisdictional statute, 28 U.S.C. § 1332. For example, the Class Action Fairness Act allows federal jurisdiction based on diversity of citizenship without total diversity; this is based on Article III's broader sweep.

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, Kentucky's highest court at the time, and lost. The railroad appealed again to the U.S. Supreme Court, which ruled in favor of the railroad,''Louisville & Nashville R.R. v. Mottley'', . thereby handing the Mottleys yet another legal defeat.

References

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