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Moore v. Chesapeake & Ohio Railway Co.

Supreme Court of the United States · 1934 · Civil Procedure

Civil ProcedurePropertyFederal jurisdictionFederal Employers' Liability ActSafety Appliance ActsDiversity jurisdictionjurisdictioncomplaint allegations

Facts

Petitioner was injured in respondent railroad's Kentucky yard while working as a switchman and attempting to uncouple freight cars; he alleged the injuries were caused by a defective uncoupling lever. His complaint contained two counts for the same injuries. The first count alleged he was employed in interstate commerce and sued under FELA, the Safety Appliance Acts, and related ICC rules; the second alleged he was employed in intrastate commerce and relied on the Safety Appliance Acts together with the Kentucky Employers' Liability Act. Respondent challenged federal jurisdiction by plea in abatement as to both counts.

Issue

Whether the federal district court in the Northern District of Indiana had jurisdiction over the first count alleging a FELA claim connected with Safety Appliance Act violations, and whether it had jurisdiction over the second count alleging a Kentucky statutory claim for injuries received in intrastate commerce that incorporated federal safety duties. More specifically, the Court asked whether the second count should be treated as arising under federal law or instead as a state-law claim supported by diversity jurisdiction.

Rule

Jurisdiction of a federal district court is determined by the allegations of the complaint. When a complaint adequately alleges every essential element of a cause of action under the Federal Employers' Liability Act, an employee injured while employed in interstate commerce may sue under FELA in connection with Safety Appliance Act violations, and venue is governed by FELA's provision allowing suit where the defendant resides, where the cause arose, or where the defendant is doing business. By contrast, a suit under a state statute governing injuries in intrastate commerce does not arise under federal law merely because the state statute incorporates duties imposed by the Federal Safety Appliance Acts; if diversity and residence requirements are met, federal jurisdiction may rest on diversity alone.

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Ethan Burke, a brakeman for Blue Valley Rail Lines, filed suit in federal district court in Toledo, Ohio. His complaint alleged that he was injured while coupling cars in the railroad's interstate operations and asserted a claim under the Federal Employers' Liability Act based in part on a defective coupler that violated federal safety-appliance requirements; the railroad was doing business in the district when suit began.

The railroad files a plea challenging subject-matter jurisdiction, asserting that Ethan was actually working only on a purely local yard assignment and therefore cannot recover under the federal statute. How should the court rule on the jurisdictional objection?

Explanation. The governing rule is that the district court's jurisdiction is determined by the allegations of the complaint. If the complaint clearly alleges the essential ingredients of a Federal Employers' Liability Act claim—such as injury while employed in interstate commerce by an interstate carrier—the case is within federal jurisdiction at the outset. The railroad's assertion that Ethan was actually engaged in intrastate work goes to the merits, not to the existence of jurisdiction based on the pleaded federal claim. (Derived from Moore v. Chesapeake & Ohio Railway Co. (1934).)