Moore v. Chesapeake & Ohio Railway Co.
291 U.S. 205, 1934 U.S. LEXIS 498, 54 S. Ct. 402 (1934)
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Rule of Law:
A suit brought under a state statute does not arise under the laws of the United States for federal question jurisdiction purposes simply because the state law incorporates a federal statute as the standard of care.
Facts:
- Moore was an employee of the Chesapeake & Ohio Railway Co. (C&O), an interstate carrier.
- On November 29, 1930, Moore was working as a switchman in C&O's rail yard in Russell, Kentucky.
- While attempting to uncouple freight cars, Moore sustained injuries.
- Moore alleged that his injuries were caused by a defective uncoupling lever on a freight car.
- Moore was a citizen of Indiana, and C&O was a corporation organized under the laws of Virginia.
- At the time the suit was commenced, C&O was doing business in the Northern District of Indiana.
Procedural Posture:
- Moore (petitioner) filed an action against Chesapeake & Ohio Railway Co. (respondent) in the U.S. District Court for the Northern District of Indiana.
- The complaint included two counts: one under the federal FELA and SAA for an interstate injury, and a second under the Kentucky Employers’ Liability Act and SAA for an intrastate injury, asserting diversity jurisdiction.
- C&O filed a plea in abatement, challenging the District Court's jurisdiction over both counts.
- The District Court overruled the plea, the case went to trial, and a jury returned a general verdict for Moore.
- C&O, as appellant, appealed the judgment to the U.S. Circuit Court of Appeals.
- The Circuit Court of Appeals reversed, holding that the District Court lacked jurisdiction to entertain either count of the complaint.
- The U.S. Supreme Court granted certiorari to review the decision of the Circuit Court of Appeals.
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Issue:
Does a suit brought under a state employer's liability act, which incorporates the federal Safety Appliance Acts as the standard of care for an intrastate commerce injury, 'arise under' the laws of the United States for the purposes of federal question jurisdiction?
Opinions:
Majority - Chief Justice Hughes
No. A suit based on a state statute does not become a suit 'arising under' the laws of the United States merely because the state law adopts a federal statute as its standard of care. The complaint's second count set forth a cause of action created by the Kentucky Employers’ Liability Act, not federal law. The Federal Safety Appliance Acts (SAA) prescribe duties but do not create a federal private right of action for injuries sustained in intrastate commerce. Instead, the right to recover for a breach of the SAA's duties in an intrastate context springs from state law. Here, the Kentucky statute created the cause of action and simply incorporated the federal safety standards as the measure of the railroad's duty. Therefore, the claim does not present a federal question, and federal court jurisdiction must be based on diversity of citizenship. Because diversity of citizenship between Moore (Indiana) and C&O (Virginia) was properly alleged and proven, the District Court had jurisdiction over this state-law claim.
Analysis:
This case is a foundational decision for understanding the limits of federal question jurisdiction under 28 U.S.C. § 1331. It clarifies that for a case to 'arise under' federal law, the federal law must create the cause of action itself, not merely provide a standard of conduct incorporated into a state-law claim. This prevents the federal courts from being inundated with state tort cases that happen to involve a federal regulation. The decision establishes a critical distinction between a claim whose source is federal law and a claim whose source is state law but which requires interpretation of a federal statute.
