Louisville & Nashville Railroad v. Mottley
211 U.S. 149 · Supreme Court of the United States · 1908
Facts
A case was brought in federal Circuit Court concerning a contract for transportation and a federal statute prohibiting free passes. The plaintiff's claim anticipated a federal defense regarding the statute's constitutionality, but there was no diversity of citizenship.
Procedural history
Two questions of law were raised by a demurrer to the bill in the Circuit Court. The case was then brought to this court by appeal. This court determined that the Circuit Court was without jurisdiction of the cause.
Issue
Did the Circuit Court have federal question jurisdiction when the plaintiff's complaint merely anticipated a federal defense, rather than basing its own cause of action on federal law?
Holding
No, the Circuit Court lacked jurisdiction because the plaintiff's complaint did not establish a federal question. The judgment was reversed, and the case was remitted with instructions to dismiss the suit for want of jurisdiction.
Rule
A suit arises under the Constitution and laws of the United States for federal question jurisdiction only when the plaintiff’s statement of their own cause of action shows that it is based upon those laws or the Constitution, not merely by alleging an anticipated federal defense.
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