Louisville & Nashville Railroad Co. v. Mottley

Louisville & Nashville Railroad Co. V. Mottley

Louisville & Nashville Railroad Co. v. Mottley

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Louisville & Nashville Railroad Company v. Mottley, 211 U.S. 149 (1908), was a United States Supreme Court decision that held that under the existing statutory scheme, federal question jurisdiction could not be predicated on a plaintiff's anticipation that the defendant would raise a federal statute as a defense. Instead, such jurisdiction can only arise from a complaint by the plaintiff that the defendant has directly violated some provision of the Constitution, laws, or treaties of the United States. This reading of the federal question jurisdiction statute is now known as the well-pleaded complaint rule.


The Mottleys were a husband and wife who had been injured in a train wreck on September 7, 1871 in Jefferson County, Kentucky. In exchange for releasing the railroad from liability, they were compensated with free passes from the Louisville and Nashville Railroad company, which were to be renewed annually. Several decades later, in 1906, the U.S. Congress banned all free passes in order to prevent them from being used to bribe government officials, and the railroad then refused to renew the Mottleys' passes. The Mottleys sued for specific performance of the rail passes in federal court. They argued that either the federal statute did not apply because they had been issued the passes decades before the law went into effect, or if the law did apply, that it was unconstitutional because it deprived them of their property (the passes). The lower federal courts...
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