Louisville & Nashville R.R. Co. v. Mottley, 211 U.S. 149 (1908)
Louisville & Nashville Railroad Co. v.
Can a federal court assume jurisdiction over a case based on a federal law defense that the plaintiff anticipates in the complaint?
For federal question jurisdiction to exist under 28 U.S.C. § 1331, the federal question must appear on the face of a well-pleaded complaint, and not in the anticipation of a defense.
The Supreme Court held that the case did not arise under federal law for the purposes of federal jurisdiction because the federal question was presented only as an anticipated defense, not as part of the plaintiff's cause of action.
Louisville & Nashville R.R. v. Mottley is crucial for its articulation of the well-pleaded complaint rule, a foundational element in determining federal jurisdiction. This case informs the practice of pleading in federal courts, ensuring that federal courts do not overreach into matters more appropriately handled by state courts. The decision delineates the jurisdictional boundaries between state and federal courts, preserving the federal judiciary for cases that genuinely 'arise under' federal law as expressed directly in a plaintiff's claim.