Louisville & Nashville R.R. Co. v. Mottley

211 U.S. 149 (1908)

Facts:

  • Plaintiffs were injured while riding in defendant’s railroad in 1871.
  • In exchange for immunity the defendant offered free lifetime transportation on their railroads.
  • The defendant complied until 1907, when it declined to renew the passes.

Procedural History:

  • Mottleys sue for breach of contract.       Defendant asked for demurrer in circuit court, judge overruled and ruled for plaintiffs

Reversed and remitted to circuit court with instructions to dismiss for want of jurisdiction.

Contentions of parties:

] Defendant: Act of Congress of June 29, 1906 prohibits free passes or free transportation.

] Plaintiff:

  1. The act of Congress does not apply to the circumstance of this case
  2. Unconstitutional: If it does apply to this case, it conflicts with the 5th Amendment because it deprives plaintiffs of their property without of due process of law.

Issue:

Whether the contract for free passes for transportation is unlawful.

Whether the statute violates the 5th Amendment.

Holding:

No decision on this because the court does not have jurisdiction.

Rule:

2-prong test:

  1. Well-pleaded complaint: least the plaintiff needs in the complaint to fully state the complaint against defendant, without anticipating response to the claim.
  2. Establishes that federal law creates the cause of action or that the plaintiff’s right of relief depends on a resolution of a question of federal law.

Reasoning:

The plaintiff does not show that a cause of action arose from the Constitution; therefore the federal courts have no jurisdiction.

Court’s Order:

Reversed and remitted to circuit court with instructions to dismiss for want of jurisdiction.