May 14, 2020

Louisville & Nashville RR Co. v. Mottley | Case Brief - 211 U.S. 149, 29 S.Ct. 42 (1908) US Supreme Court

FACTS: All parties are residents of Kentucky. Appellees were injured on the railroad trip and given free life passes until 1907 when the appellant did not give them the passes saying it violated an Act of Congress.

HISTORY: Demurrer overruled, decree for relief prayed for.

ISSUE: Was jurisdiction of the Circuit Court exceeded?

RATIONALE: Cause of action must arise under the constitution and not in anticipation of defense by the defendant.

DISPOSITION: Reversed and remitted to circuit court with instructions to dismiss for want of jurisdiction.


 - present statute is 28 U.S.C. 13331

 - constitutional scope is very broad

 - plaintiff cannot anticipate a federal defense in their complaint and use that defense as a basis for federal jurisdiction

- "well-pleaded complaint rule"