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Louisville & Nashville Railroad v. Mottley

Supreme Court of United States
211 U.S. 149 (1908)
ELI5:

Rule of Law:

For a suit to 'arise under' the Constitution and laws of the United States, giving a federal court jurisdiction, the plaintiff's own statement of the cause of action must be based upon federal law. Jurisdiction cannot be established by a plaintiff's complaint that merely anticipates a defense based on federal law.


Facts:

  • In 1871, Mr. and Mrs. Mottley were injured in a railway accident.
  • To settle their claims for damages, the Louisville & Nashville Railroad Company agreed to issue them free transportation passes for the rest of their lives.
  • The railroad honored this agreement for over thirty years.
  • In 1906, Congress passed an act forbidding railroads from giving free transportation.
  • In 1907, the railroad refused to renew the Mottleys' passes, citing the 1906 act of Congress as its reason for non-performance.

Procedural Posture:

  • The Mottleys filed a suit for specific performance of a contract against the Louisville & Nashville Railroad Company in the Circuit Court of the United States for the Western District of Kentucky.
  • The railroad company filed a demurrer to the Mottleys' complaint, effectively a motion to dismiss.
  • The Circuit Court overruled the railroad's demurrer.
  • The railroad company appealed that decision to the Supreme Court of the United States.

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Issue:

Does a federal court have original jurisdiction over a case where the plaintiff's cause of action is for breach of a state-law contract, but the complaint anticipates a defense based on a federal statute and asserts that the statute is unconstitutional as applied to their contract?


Opinions:

Majority - Mr. Justice Moody

No. 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. The Mottleys' claim is for breach of contract, a cause of action that arises under state law, not federal law. The federal question only appears because the Mottleys' complaint anticipates the railroad's defense—that a 1906 federal statute prevents it from honoring the contract—and then argues against that defense on constitutional grounds. Citing precedent like Tennessee v. Union & Planters' Bank, the Court affirmed that jurisdiction is determined by the cause of action itself, not by defenses that might be raised or anticipated. The plaintiff's original cause of action, not the potential defenses, must be the source of the federal question.



Analysis:

This case is a cornerstone of federal civil procedure, establishing the 'well-pleaded complaint' rule for federal question jurisdiction. It significantly narrows the path into federal court by clarifying that the federal issue must be a necessary element of the plaintiff's claim, not merely a response to an anticipated defense. This prevents federal courts from hearing a vast number of state-law cases that might tangentially involve a federal law. The decision reinforces the principle that the plaintiff is the 'master of the complaint' but cannot strategically plead anticipated federal defenses to manufacture federal jurisdiction where it would not otherwise exist.

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