The United States Supreme Court case Louisville & Nashville Railroad Co. v. Mottley, 211 U.S. 149 (1908), stands as a landmark decision in American civil procedure. The Court, in this case, set out a fundamental limitation on the jurisdiction of federal courts when dealing with federal question cases. It held that federal jurisdiction cannot be predicated on a plaintiff’s anticipation that the defendant will raise a federal statute as a defense.
Instead, jurisdiction can only exist if the plaintiff’s own complaint alleges a violation of the Constitution, federal law, or treaties of the United States. This doctrine came to be known as the well-pleaded complaint rule, a principle still central to jurisdictional analysis today.
Citation
Louisville & Nashville Railroad Co. v. Mottley, 211 U.S. 149, 29 S. Ct. 42, 53 L. Ed. 126 (1908).
Facts of Louisville & Nashville Railroad Co. v. Mottley
Erasmus and Annie Mottley, a married couple, were injured in a train accident on September 7, 1871, in Jefferson County, Kentucky. To settle their personal injury claims, the Louisville and Nashville Railroad Company provided them with lifetime passes for free transportation on its lines. These passes were to be renewed annually, and for decades, the arrangement was honored.
However, in 1906, Congress enacted the Hepburn Act, a piece of federal legislation designed in part to curb corruption in the railroad industry. Among other things, the Act prohibited the issuance of free passes for travel, effective January 1, 1907. The purpose of the prohibition was to prevent railroads from using free passes to influence or bribe government officials.
When the Mottleys sought renewal of their free passes in 1907, the Louisville and Nashville Railroad Company refused, citing the prohibition in the Hepburn Act. In response, the Mottleys filed suit in federal court seeking specific performance of their contract with the railroad. They argued that the Hepburn Act did not apply to them since the passes had been issued as part of a settlement decades before the law went into effect. In the alternative, they contended that if the law did apply to them, it was unconstitutional because it deprived them of their property without due process of law.
The lower federal courts ruled in favor of the Mottleys. The case was then appealed to the United States Supreme Court.
Issue
The primary question before the Supreme Court was whether the case could properly be heard in federal court. More specifically, the Court considered whether federal question jurisdiction existed when the plaintiff’s complaint raised no direct federal claim but instead merely anticipated that a federal law—the Hepburn Act—would be raised by the defendant as a defense.
Procedural History
- 1871 – Erasmus and Annie Mottley were injured in a railroad accident. They accepted lifetime free passes as settlement.
- 1906 – Congress passed the Hepburn Act, prohibiting free passes beginning in 1907.
- 1907 – The Louisville and Nashville Railroad Company refused to renew the passes.
- Federal Trial Court – The Mottleys sued in federal court, seeking specific performance. The trial court ruled in their favor.
- Appeal – The case reached the Supreme Court of the United States, where the Court raised the question of subject matter jurisdiction sua sponte (on its own motion).
Opinion of the Court in Louisville & Nashville Railroad Co. v. Mottley
Justice William H. Moody delivered the opinion of the Court. The Supreme Court dismissed the case for lack of jurisdiction. The Court reasoned that the plaintiffs had not established any basis for federal jurisdiction under the statutory scheme governing federal question cases.
- There was no diversity of citizenship between the parties, which could have independently provided federal jurisdiction.
- The plaintiffs’ cause of action itself was based purely on contract law, a matter of state law. Their claim was simply that the railroad had breached its agreement to provide lifetime passes.
- The plaintiffs had referenced federal law—the Hepburn Act—only to anticipate a potential defense by the railroad. Their complaint stated that if the railroad argued the Act invalidated the passes, then the Act either did not apply or was unconstitutional.
The Court emphasized that a suit “arises under” federal law for jurisdictional purposes only when the plaintiff’s well-pleaded complaint shows that federal law forms the basis of the plaintiff’s cause of action. A plaintiff cannot secure federal jurisdiction by asserting in the complaint that the defendant will rely on federal law as a defense and then contesting that defense.
Thus, the Supreme Court concluded that the case could not be brought in federal court and ordered it dismissed for want of jurisdiction.
Conclusion
Louisville & Nashville Railroad Co. v. Mottley stands as one of the most important cases in the development of federal jurisdiction. By refusing to allow anticipated defenses to serve as the basis for federal question jurisdiction, the Supreme Court drew a firm line regarding the authority of federal courts. The case illustrates how jurisdictional statutes can be more restrictive than the Constitution itself, and how those restrictions serve to maintain a careful balance between federal and state courts.
The doctrine of the well-pleaded complaint rule, first articulated in this decision, remains essential for determining whether a case belongs in federal court. It ensures that federal jurisdiction is reserved for cases where the plaintiff’s cause of action itself arises under federal law, thereby reinforcing the principle that not all disputes touching on federal issues are appropriate for federal adjudication.