Does a federal court have jurisdiction over a case solely because it involves interpretation of the U.S. Constitution or federal laws?

The Louisville and Nashville Railroad Company had previously given free railroad passes to the Mottleys as compensation for a valid claim. In 1906, Congress passed legislation prohibiting the issuance of free passes and mandating uniform compensation for passenger transportation as specified in filed tariffs. Anticipating that the railroad would use this new law to avoid honoring their contract, the Mottleys initiated a lawsuit in federal court. The railroad company subsequently appealed the case to the Supreme Court.

The plaintiff initially filed the case in the Circuit Court of the United States for the Western District of Kentucky. Subsequently, the railroad company submitted a demurrer to the bill, which raised two legal questions. These questions were then brought before the Supreme Court on appeal.

(Moody, J.)

No. Federal court jurisdiction is not established merely because a case involves interpretation of the U.S. Constitution or federal laws. Jurisdiction only arises when the plaintiff's own statement of their cause of action demonstrates that it is based on federal law or the Constitution. Anticipating a federal defense is insufficient to confer jurisdiction. The well-pleaded complaint rule governs federal question jurisdiction. This principle stems from the statutory language granting jurisdiction over cases "arising under" federal law. A case does not arise under federal law simply because a federal issue may be involved; rather, the federal question must be an essential element of the plaintiff's claim. This interpretation preserves the limited nature of federal court jurisdiction and respects the role of state courts in adjudicating most disputes. It prevents plaintiffs from manufacturing federal jurisdiction by anticipating potential defenses. The rule also promotes judicial efficiency by allowing courts to determine jurisdiction based solely on the complaint, without speculating about possible defenses. Numerous precedents reinforce this interpretation, establishing it as a fundamental principle of federal jurisdiction. This approach maintains the balance between state and federal judicial systems, ensuring that federal courts remain courts of limited jurisdiction as envisioned by the Constitution and Congress.