Louisville & Nashville Railroad Co. v. Mottley 211 U.S. 149 (1908) Parties The Mottleys (husband and wife) are the plaintiffs. The defendants are Louisville & Nashville Railroad Co. All members of both parties are from Kentucky. Synopsis of facts While the plaintiffs were aboard a train on the passenger’s railroad in 1871, they were injured because of the defendant’s negligence. Instead of suing, the plaintiffs released their claims for damages in exchange for transportation during their lives, which was expressed through a contract between the parties. They stopped the contract on January 1, 1907, where the defendants declined to renew the passes of the plaintiffs. The defendants claimed that the congressional statue that was passed on June 29, 1906, was the reason they were no longer going to honor the terms of the contract. Procedural History The plaintiffs, Mottleys, brought action against the defendants, to compel the specific performance of a contract between the two parties, in the circuit court of the United States in the Western district of Kentucky. The defendants of the case demurred (‘a procedural device…to assert that the plaintiff’s complaint is legally insufficient because the law doesn’t provide a remedy for the conduct alleged” (pg. 93)). The circuit court judge overruled the demurer and gave a decree for relief. The defendant appealed to the United States Supreme court. Issue Did the plaintiffs express a constitutional/federal issue in their initial claim? Inherited Rule 28. U.S.C Section 1331 “Grants jurisdiction to the federal district court over all cases “arising under the Constitution, laws, or treaties of the United States’ (pg. 92). - “Arising-under jurisdiction” Holding No, they provided the constitutional issue when bringing up the defendants assumed defense. “The judgement was reversed and remitted to the circuit court with instruction to dismiss the suit for want of jurisdiction” (pg. 96). Reasoning/Analysis Because the plaintiffs alleged in their claim that the defendants would bring up the issues of the Constitution or federal statutes, they expressed want/desire for jurisdiction. Rather, the complaint against the defendants should have been confined to its cause of actions. They should not have claimed what the argument of the defendants would be or answered the defense that they might use in their initial complaint. So, for a federal question to be presented, it must arise in the initial complaint under what the cause of action is, rather than the plaintiffs stating their cause of action and then bringing the federal question into it under the defendant’s defense. -In this case, the original issue was a contract breach, “therefore the suit “arose under” contract law, which is state law. Therefore, Mottley did not satisfy the Holmes test” (pg. 102). Subsequent Rule -Osborn v. Bank of the United States -So long as there is a federal ingredient in the action-whether it is introduced by the plaintiff’s claims or by a defense asserted in the defendant’s answer-Osborn holds that Article 3, Section 2 grants federal question jurisdiction over the case” (pg. 93). -if the “original cause” (the basic suit) involves a question of federal law, the case arises under federal law. Tennessee v. Union and Planters Bank Inc. - “A suggestion of one party, that the other will or may set up a claim under the Constitution or laws of the United States, does not make the suit one arising under that Constitution or those laws” (pg. 95). Relevant Subsequent Rule -Well-pleaded complaint rule -The Mottley case illustrates the well-pleaded complaint rule. Under this rule a case can “arise under” federal law, “if the federal issue appears on the face of the well-pleaded complaint, that is, if a proper complaint, limited to the allegations necessary to state a proper claim for relief, relies on federal law” (pg. 97). -Mottley Rule -“The Mottley rule allows the court to determine its jurisdiction without demanding an immediate answer to the complaint or relying on the plaintiffs representations about likely defenses” (pg. 99). -“The analysis must focus on the allegations in the plaintiffs complaint, not potential defenses the defendant might assert in her answer” (pg. 102).