Louisville and Nashville Railroad Co. v. Mottley

1908

Venue: SCOTUS

Facts: The Mottleys are injured in some kind of railway accident, and they get free passes for life in exchange for a covenant not to sue. Then the railroad declines to honor the passes, citing a new act of congress that invalidates this kind of deal.

Posture: Lower court finds for the plaintiffs.

Issue: Is the statute valid? Does it indeed make the Mottleys' contract invalid?

Holding: No need to worry about the merits: the court below had no jurisdiction. Reversed and remanded with instructions to dismiss.

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 it was based upon those laws or that constitution (the well-pleaded complaint rule).

Reasoning: The fact that a defendant might assert a federal defense doesn't mean you can bring your case in federal court.

Dicta: The court can raise the question of jurisdiction on its own-- it doesn't have to be one of the parties.