Louisville & Nashville R. Co. v. Mottley – Case Brief
Louisville & Nashville R. Co. v. Mottley, 211 U.S. 149, 152 (1908).
Facts: Mottley and his wife (P) were injured while riding on the Louisville & Nashville Railroad (D) in 1871. A settlement was reached whereby Mottley would release claims for damages against D in exchange for a contract that granted them free transportation for life. D refused to renew P’s pass in 1907 because an act of Congress forbade the giving of free passes or free transportation. P filed an action in federal court in the Western District of Kentucky. Both P and D were citizens of Kentucky and diversity was therefore unavailable. P claimed that D would raise a constitutional defense in his answer thereby creating federal subject matter jurisdiction.
The court tried the case on the merits and entered judgment in favor of P. D appealed directly to the Supreme Court. The Supreme Court sua sponte raised the issue of whether the federal courts had jurisdiction to hear the case.
Issue: 1) Does the mere allegation of an anticipated defense that arises under federal law create a federal question giving a federal court jurisdiction? 2) May a suit be dismissed at the appellate level for subject matter jurisdiction?
Holding and Rule (Moody): 1) 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. 2) Yes. A suit may be dismissed at the appellate level for 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. P’s complaint was based on a contract claim and did not raise a federal question.
Disposition: Reversed to be dismissed for lack of jurisdiction.
Notes: 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.