Louisville & Nashville Railroad Co. v. Mottley
Encyclopedia
Louisville & Nashville Railroad Company v. Mottley, 211 U.S. 149
(1908), was a United States Supreme Court
decision that held that under the existing statutory scheme, federal question jurisdiction
could not be predicated on a plaintiff
's anticipation that the defendant
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
, laws, or treaties of the United States
. This reading of the federal question jurisdiction statute is now known as the well-pleaded complaint rule.
on September 7, 1871 in Jefferson County, Kentucky
. In exchange for releasing
the railroad from liability, they were compensated with free passes from the Louisville and Nashville Railroad
company, which were to be renewed annually. Several decades later, in 1906, the U.S. Congress banned all free passes in order to prevent them from being used to bribe government officials, and the railroad then refused to renew the Mottleys' passes. The Mottleys sued for specific performance
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.
, questioned the existence of subject matter jurisdiction, transforming the issue into whether this was a case that could have been brought in federal court in the first place.
, dismissed the case for lack of jurisdiction. There was no diversity of citizenship
, and no grounds for federal question jurisdiction
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.
(1911)), thereby handing the Mottleys yet another legal defeat.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1908), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision that held that under the existing statutory scheme, federal question jurisdiction
Federal question jurisdiction
Federal question jurisdiction is a term used in the United States law of civil procedure to refer to the situation in which a United States federal court has subject-matter jurisdiction to hear a civil case because the plaintiff has alleged a violation of the Constitution or law of the...
could not be predicated on a plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
's anticipation that the defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
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
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
, laws, or treaties of the United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
. This reading of the federal question jurisdiction statute is now known as the well-pleaded complaint rule.
Facts
The Mottleys were a husband and wife who had been injured in a train wreckTrain wreck
A train wreck 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 accident, such as when a train wheel jumps off a track in a derailment; or when a boiler...
on September 7, 1871 in Jefferson County, Kentucky
Jefferson County, Kentucky
As of the census of 2000, there were 693,604 people, 287,012 households, and 183,113 families residing in the county. The population density was . There were 305,835 housing units at an average density of...
. In exchange for releasing
Legal release
A legal release is a legal instrument that acts to terminate any legal liability between the releasor and the releasee, signed by the releasor. A release may also be made orally in some circumstances...
the railroad from liability, they were compensated with free passes from the Louisville and Nashville Railroad
Louisville and Nashville Railroad
The Louisville and Nashville Railroad was a Class I railroad that operated freight and passenger services in the southeast United States.Chartered by the state of Kentucky in 1850, the L&N, as it was generally known, grew into one of the great success stories of American business...
company, which were to be renewed annually. Several decades later, in 1906, the U.S. Congress banned all free passes in order to prevent them from being used to bribe government officials, and the railroad then refused to renew the Mottleys' passes. The Mottleys sued for specific performance
Specific performance
Specific performance is an order of a court which requires a party to perform a specific act, usually what is stated in a contract. It is an alternative to award/ for awarding damages, and is classed as an equitable remedy commonly used in the form of injunctive relief concerning confidential...
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 sponteSua sponte
In law, sua sponte describes an act of authority taken without formal prompting from another party. The term is usually applied to actions by a judge taken without a prior motion or request from the parties...
, questioned the existence of subject matter jurisdiction, 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 MoodyWilliam Henry Moody
William Henry Moody was an American politician and jurist, who held positions in all three branches of the Government of the United States.-Biography:...
, dismissed the case for lack of jurisdiction. There was no diversity of citizenship
Diversity jurisdiction
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction in civil procedure in which a United States district court has the power to hear a civil case where the persons that are parties are "diverse" in citizenship, which generally indicates that they are...
, and no grounds for federal question jurisdiction
Federal question jurisdiction
Federal question jurisdiction is a term used in the United States law of civil procedure to refer to the situation in which a United States federal court has subject-matter jurisdiction to hear a civil case because the plaintiff has alleged a violation of the Constitution or law of the...
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 & N. R. Co. v. Mottley, 219 U.S. 467Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1911)), thereby handing the Mottleys yet another legal defeat.