Louisville & Nashville Railroad Co. v. Mottley
211 U.S. 149, 29 S. Ct. 42, 53 L. Ed. 126 (1908)
Mottleys were a husband and wife who had been injured in a train mishap,
and had been compensated with free passes from the railroad company.
decades later, Congress banned free passes in order to prevent
their use as bribes, and the railroad then refused to renew the Mottley's
Mottleys sued to enforce their compensation, bringing their case in
Federal Court under the theory that the railroad's refusal to honor the
passes was based on an unconstitutional law.
Federal Trial Court decided in favor of the Mottleys, the railroad
Federal Appellate Court affirmed.The railroad appealed.
US Supreme Court dismissed the case for lack of jurisdiction.
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
case revolved around breach of contract and specific performance.These are State
laws.The defense was that
there was a Federal law which barred contract.But, the claim here was of State law, only the defense was a question of Federal law.
only way a party can get federal question jurisdiction is if the federal question arises in the
plaintiff's well-pleaded complaint.
suit arises under Federal law only if the original statement of the
plaintiff's cause of action shows that it is based on the Constitution
or Federal statutes.
is known as the well-pleaded complaint rule.
Federal Court can't have jurisdiction just because the defendant might
use a Federal law or the Constitution to defend himself.
the dismissal of their case, the Mottleys brought a similar action in
their State Court. They lost in the State Court, and appealed their loss
all the way to the US Supreme Court, where they faced yet another legal
Courts can decide matters of Federal law.