Louisville & Nashville Railroad Co. v. Mottley
SCOTUS - 1908 (211 U.S. 149)
- Ps were injured while passengers on a train operated by D.
- P released their claims against D in consideration for the promise that D would provide P with free transportation for life. D honored this agreement for 30 years.
- Congress passed a statute that prohibited railroads from giving free passes or providing free transportation.
- P sued D in a federal circuit court claiming a breach of contract.
- Circuit Court found for P, D breached contract.
- SCOTUS found there was no federal jurisdiction, matter dismissed.
- Is federal-question jurisdiction valid in cases that do not arise under the Constitution or federal law but merely anticipate that the D will argue a federal or Constitutional matter as its defense?
- Federal-question jurisdiction is not valid in cases that do not arise under the Constitution or federal law but merely anticipate that the D will argue a federal or Constitutional matter as its defense.
- Only allegations pertaining to the necessary elements of the P's claim will be considered in determining if the case arises under federal law.
- There was no diversity of citizenship. The only grounds for jurisdiction is in the arising under language.
- A suit arises under the Constitution and laws of the US only when the P's statement of his own cause of action shows that it is based upon those laws or the Constitution.
- It is not enough that the P alleges some anticipated defense to his cause of action, and asserts that the defense is invalidated by some provision of the Constitution of the US.
- It is improper in order to prove P's cause of action to go into any matters of defense which the Ds might possibly set up and then attempt to reply to such defense in order to show that a federal cause of action might or probably would arise in the courts of the trial of the case.