Louisville & N. R. Co. v. Mottley

211 U.S. 149, 29 S. Ct. 42 (1908)

 

RULE:

A suit arises under the Constitution and laws of the United States only when the plaintiff's statement of his own cause of action shows that it is based upon those laws or that Constitution. It is not enough that the plaintiff alleges some anticipated defense to his cause of action and asserts that the defense is invalidated by some provision of the Constitution of the United States. 

FACTS:

Appellant, a railroad company, entered into a contract with appellees, a married couple, to give them travel passes every year. When a new federal law prohibited railroads from issuing free passes, appellant declined to renew the passes. Appellees sued in federal court for specific performance of the contract, and the circuit court granted an injunction. 

ISSUE:

Is the anticipated defense contained in the plaintiff’s complaint enough to establish subject matter jurisdiction in federal court?

ANSWER:

No.

CONCLUSION:

The Supreme Court of the United States, finding it improper to plead that a defense under federal law was anticipated, reversed the judgment and remanded to the circuit court with instructions to dismiss the action for lack of federal question jurisdiction. There was no diversity of citizenship and it is not and cannot be suggested that there was any ground of jurisdiction, except that the case was a "suit . . . arising under the Constitution and laws of the United States." Act of August 13, 1888, c. 866, 25 Stat. 433, 434. It is the settled interpretation of these words, as used in this statute, conferring jurisdiction, that a suit arises under the Constitution and laws of the United States only when the plaintiff's statement of his own cause of action shows that it is based upon those laws or that Constitution. It is not enough that the plaintiff alleges some anticipated defense to his cause of action and asserts that the defense is invalidated by some provision of the Constitution of the United States. Although such allegations show that very likely, in the course of the litigation, a question under the Constitution would arise, they do not show that the suit, that is, the plaintiff's original cause of action, arises under the Constitution.

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