Louisville & Nashville R.R. Co. v. Mottley

Brief Fact Summary.

Appellees sued Appellants to enforce a contract guaranteeing free travel. Appellants argued the contract was unenforceable because of a new congressional act forbidding free travel.

Synopsis of Rule of Law.

A lawsuit arises under the Constitution, laws, or treaties of the U.S., for purposes of establishing federal question jurisdiction, only when the plaintiff sufficiently alleges in the original cause of action that a law, treaty, or Constitution has been violated.

Facts.

The Mottleys (Appellees), citizens of Kentucky, sued Louisville & Nashville Railroad Co. (Appellants), a Kentucky train company, for an injury on the railroad in Kentucky. The suit was settled with a contract guaranteeing Appellees free travel passes each year. This contract was enforced for thirty-six years, until Appellants refused to renew the pass because of a congressional act that forbid free transportation. Appellees brought suit to enforce the contract and Appellant demurred.

Issue.

Is federal question jurisdiction established where the only reference to federal law is an anticipated defense?

Held.

No, an anticipated defense does not establish federal question jurisdiction. The judgment is reversed.

Discussion.

The Appellees did not have federal question jurisdiction or diversity jurisdiction. The Court determined that the parties were not citizens of different states, and Appellee’s anticipation that the Appellant would raise the congressional act as a defense to enforcement of the contract was not sufficient to demonstrate that the original cause of action arose from a violation of the Constitution.