Louisville & Nashville R.R. v. Mottley
Citation: 211 U.S. 149 (1908)
Facts
The Mottleys were injured in a railroad accident and settled their claims in exchange for lifetime free passes. Congress later passed a statute prohibiting free railroad passes. When the railroad refused to honor the passes, the Mottleys sued in federal court, arguing the railroad’s reliance on the federal statute violated the Fifth Amendment. Jurisdiction was asserted on federal question grounds.
Issue
Does federal question jurisdiction exist when the federal issue appears only in the plaintiff’s anticipated defense to the defendant’s anticipated defense?
Holding
No. The Supreme Court dismissed the case for lack of jurisdiction even though neither party raised the issue. Federal question jurisdiction requires that the plaintiff’s own cause of action arise under federal law — not merely that the plaintiff anticipates a federal defense.
Rule
Well-pleaded complaint rule: Federal question jurisdiction under 28 U.S.C. § 1331 exists only if the federal issue appears on the face of the plaintiff’s well-pleaded complaint — i.e., in the statement of the plaintiff’s cause of action, not in the defendant’s anticipated defense or the plaintiff’s anticipated reply to a defense.
Significance
- Establishes the well-pleaded complaint rule — one of the most important jurisdictional rules in federal practice
- Federal question jurisdiction cannot be based on anticipated federal defenses (e.g., preemption as a defense does not create federal jurisdiction, with narrow exceptions)
- Courts must raise subject matter jurisdiction defects sua sponte even if parties do not object
- The Mottleys ultimately prevailed on the merits in state court — the jurisdictional dismissal was not a loss on the substance