Louisville & Nashville Railroad v. Motley case brief summary

Louisville & Nashville Railroad v. Motley (US 1908) – Motleys are given lifetime railroad passes as compensation for injuries incurred.  Federal statute is subsequently enacted that prohibits issuance of lifetime passes.  Motleys attempt to sue for breach of contract in federal anticipating the railroad will use federal statute as defense.

a.       Holding: federal question jurisdiction does not apply.

b.      Ruling: this is not a federal issue but a state law cause of action for breach of contract.  To bring a suit in federal court, the federal issue must establish the claim. Motley’s do not need to address federal issue to prove their breach of contract claim.

c.       Note: Motley’s ultimately get to Supreme Court after going through state courts via 28 USC 1257.