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Louisville & Nashville Railroad Co. v. Mottley

Supreme Court of the United States · 1908 · Civil Procedure

Civil Proceduresubject matter jurisdictionfederal questionwell-pleaded complaint rulesubject matter jurisdictionfederal questionarising underwell-pleaded complaint

Facts

The plaintiffs brought suit in federal Circuit Court to enforce a contract for transportation against the railroad. The demurrer raised questions about whether a federal statute of June 29, 1906 made performance of that contract unlawful and, if so, whether the statute violated the Fifth Amendment. There was no diversity of citizenship, so the only possible basis for jurisdiction was that the suit arose under the Constitution or laws of the United States. The plaintiffs' assertion of federal law appeared in response to an anticipated defense based on the federal statute.

Issue

Whether the federal Circuit Court had federal question jurisdiction where the plaintiffs' own cause of action did not itself arise under federal law, but the complaint anticipated a defense under a federal statute and alleged that defense would be invalid under the Constitution.

Rule

A suit arises under the Constitution or laws of the United States only when the plaintiff's own statement of his cause of action shows that it is based on federal law or the Constitution. It is not enough that the plaintiff anticipates a defense to his cause of action and asserts that the defense is invalidated by the Constitution or federal law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Alvarez of Kentucky sues Blue Crest Transit Co. in federal court in Louisville for breach of a transportation contract created under Kentucky law. Her complaint alleges that Blue Crest will argue a federal transportation statute bars enforcement, and she further alleges that if the statute is read that way it violates the U.S. Constitution.

Assuming there is no diversity jurisdiction, does the federal court have subject matter jurisdiction?

Explanation. Federal question jurisdiction exists only when the plaintiff's own statement of her cause of action shows that it is based on the Constitution or laws of the United States. A plaintiff cannot create arising-under jurisdiction by alleging an anticipated federal defense and then asserting that the defense is invalid under federal law. Here, Nina's underlying claim is a state-law contract claim, so there is no federal question jurisdiction. (Derived from Louisville & Nashville Railroad Co. v. Mottley (1908).)