Louisville & Nashville R.R. Co. v. Motley

Brief Fact Summary.

Plaintiffs that settle a personal injury suit settle with the defendant for lifetime railroad passes, but are denied those passes after Congress passes a law outlawing free transportation tickets. Plaintiffs attempt to sue in federal court but are unable to because federal question jurisdiction requires the plaintiff’s claim arise under a Constitutional provision or federal law.

Synopsis of Rule of Law.

In order to a federal court to have jurisdiction over a case arising out of the Constitution or federal law, the plaintiff must state a claim based on federal law or the Constitution.

Facts.

Plaintiffs Mottleys were injured on Defendant Louisville & Nashville Railroad’s train in 1871. Defendant settled with Plaintiffs with lifetime passes for free transportation on the rail line. Congress passed an act in 1906 making it illegal for railroads to give free transportation. In 1907 when Plaintiffs attempted to renew their lifetime passes according to their settlement agreement but Defendant refused based on the new Congressional law. Plaintiffs claimed the act did not apply to their free passes and that if it did it would deprive them of their Fifth Amendment rights.

Issue.

For a federal court to have jurisdiction over a case arising out of the Constitution or federal law, must the plaintiff state a claim based on those laws or the Constitution?

Held.

Yes. For federal question to exist, a plaintiff’s claim must show that their cause of action arises under the Constitution or federal law. Decision of the trial court reversed and case remanded with instructions to dismiss for lack of jurisdiction.

Discussion.

1. Federal question jurisdiction is based on a well-pleaded complaint, not a defense the plaintiff anticipates the defendant will use.
2. Plaintiff’s complaint must allege that the defendant violated the Constitution or a federal law.