Louisville & Nashville Railroad Co. v. Mottley is one of the most foundational cases in American civil procedure, especially with respect to federal question jurisdiction. The United States Supreme Court used this case to articulate what is now known as the well-pleaded complaint rule, a doctrine that determines when a case “arises under” federal law for purposes of federal subject matter jurisdiction.
The holding in Louisville & Nashville Railroad Co. v. Mottley remains a cornerstone of jurisdictional analysis and continues to be studied in nearly every first-year civil procedure course in the country.
Facts of Louisville & Nashville Railroad Co. v. Mottley
Erasmus and Annie Mottley, a married couple, were injured in a train wreck on September 7, 1871, in Jefferson County, Kentucky. The accident involved the Louisville and Nashville Railroad. To resolve their injury claims, the Mottleys agreed to release the railroad company from liability in exchange for free lifetime passes that entitled them to transportation on the Louisville and Nashville Railroad line. These passes were to be renewed every year.
For decades, the arrangement continued without dispute. However, in 1906, Congress enacted the Hepburn Act, which included a provision prohibiting certain types of free railroad passes beginning on January 1, 1907. The purpose of the ban was to prevent railroads from using free passes as a means of influencing or bribing government officials.
After the Hepburn Act took effect, the Louisville and Nashville Railroad refused to renew the Mottleys’ passes for 1907. In response, the Mottleys filed suit seeking specific performance—that is, a court order requiring the railroad to honor the agreement and issue the free passes.
In their complaint, the Mottleys advanced two theories:
- The Hepburn Act did not apply to their free passes because the passes had been issued decades before the statute was enacted; or
- If the statute did apply, then it was unconstitutional because it deprived them of property rights in violation of the Constitution.
The Mottleys filed their case in federal court, where the lower federal courts ruled in their favor. The railroad then appealed to the United States Supreme Court. At this stage, the case was known as Louisville & Nashville Railroad Co. v. Mottley, and the focus of the Supreme Court’s analysis shifted to a threshold question: whether a federal court had subject matter jurisdiction over the case in the first place.
Issue
The issue in Louisville & Nashville Railroad Co. v. Mottley arose sua sponte—that is, the Supreme Court raised it on its own initiative. The question was:
Does a federal court have federal question jurisdiction when the plaintiff anticipates that the defendant will raise a federal statute as a defense, and the plaintiff’s complaint addresses that anticipated defense?
In other words, could the Mottleys create federal jurisdiction simply by stating in their complaint that the railroad would rely on the Hepburn Act as a defense and that the Act was invalid or inapplicable?
Louisville & Nashville Railroad Co. v. Mottley Judgment
No. The Supreme Court held that federal question jurisdiction cannot be established based on a plaintiff’s anticipation of a federal defense. Because the Mottleys’ claim was fundamentally a breach-of-contract action seeking specific performance, and because the federal question appeared only in their attempt to predict and counter a defense, the case did not arise under federal law within the meaning of the federal question jurisdiction statute.
The Supreme Court therefore dismissed the case for lack of subject matter jurisdiction and remanded it to the circuit court with instructions to dismiss.
Reasoning in Louisville & Nashville Railroad Co. v. Mottley
In Louisville & Nashville Railroad Co. v. Mottley, the Supreme Court, in an opinion written by Justice Moody, emphasized that the judiciary has an independent obligation to verify subject matter jurisdiction, even if the parties themselves do not raise the issue. The Court noted that it must always confirm that a case comes within the scope of its jurisdiction as defined by Congress.
The Court began by examining the nature of the Mottleys’ complaint. Their underlying claim was a contract dispute—they wanted the railroad to honor the free passes that had been promised to them decades earlier. The complaint did not assert that the railroad had violated any federal statute or constitutional provision.
Instead, the Mottleys anticipated that the railroad would argue that the Hepburn Act prevented them from renewing the passes. The Mottleys’ complaint responded by arguing either that the Act did not apply to their case or that, if it did, it was unconstitutional.
The Supreme Court held that this approach was insufficient to establish federal question jurisdiction. The federal question must arise from the plaintiff’s own cause of action, not from an expected defense. Because the Mottleys’ contract claim did not depend on federal law, the case did not qualify as one “arising under” the laws of the United States.
The Court also clarified that its interpretation applied specifically to the jurisdictional statute, not to Article III of the Constitution. Article III’s “arising under” language is broader and gives Congress discretion to define the scope of federal question jurisdiction. Congress had chosen, through statute, to narrow that scope, and the Court was bound to apply the statutory limits.
Conclusion
Louisville & Nashville Railroad Co. v. Mottley remains a foundational authority on federal jurisdiction. The case teaches that a plaintiff cannot invoke federal question jurisdiction merely by anticipating that a federal question will arise in defense.
Instead, the federal issue must appear on the face of a well-pleaded complaint as part of the plaintiff’s own cause of action. Through this ruling, the Supreme Court established a jurisdictional framework that continues to govern federal civil litigation.
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