Louisville & Nashville Railroad v. Mottley – Case Brief Summary
Summary of Louisville & Nashville R. Co. v. Mottley, 211 U.S. 149 (1908).
Mottley and his wife (P) were injured while riding a train on the Louisville & Nashville Railroad (D) in 1871. A settlement was reached in a personal injury lawsuit whereby Mottley would release claims for damages against the railroad in exchange for a contract that granted them free transportation for life. The railroad refused to renew the Mottleys’ pass in 1907 because an act of Congress forbade the giving of free passes or free transportation.
Mottley filed an action in federal court in the Western District of Kentucky. Diversity jurisdiction was unavailable because Mottley was domiciled in Kentucky and the railroad was incorporated in Kentucky. Mottley contended that Louisville & Nashville Railroad would raise a constitutional defense in its answer thereby creating federal subject matter jurisdiction.
The court tried the case on the merits and entered judgment for Mottley. The railroad appealed directly to the Supreme Court which sua sponte raised the issue of whether the federal courts had jurisdiction to hear the case.
- Does the mere allegation of an anticipated defense that arises under federal law create a federal question giving a federal court jurisdiction?
- May a suit be dismissed at the appellate level for lack of subject matter jurisdiction?
Holding and Rule (Moody)
- No. The mere allegation of an anticipated defense that arises by some provision of the Constitution does not create a federal question giving a federal court jurisdiction.
- Yes. A suit may be dismissed at the appellate level for lack of subject matter jurisdiction.
Anticipating that a defendant will raise a defense that includes a federal question is not sufficient to claim subject matter jurisdiction. There was no diversity of citizenship and the only way to maintain this suit would be if it arose under the Constitution or laws of the United States. The court held that the mere allegation that a defendant will raise a federal question in his answer is not sufficient to create jurisdiction. Mottley’s complaint was based on a contract claim and did not raise a federal question.
A suit already tried may be dismissed for lack of subject matter jurisdiction. In this case neither party raised the jurisdictional issue. The court raised the issue sua sponte and found that the federal question jurisdiction alleged by the plaintiff did not exist.
Subject matter jurisdiction does not exist where there is merely the anticipation of the raising of a federal question in a reply. It is not sufficient that the complaint mentions some anticipated defense and asserts that the validity of the defense is governed by federal law.
See Martin v. Hunter’s Lessee for a constitutional law case brief in which the Supreme Court held that had appellate jurisdiction over cases involving a federal question on appeal from state courts.