Monday, February 11, 2013

Louisville & N. R. Co. v. Mottley case brief

Louisville & N. R. Co. v. Mottley case brief summary 

211 U.S. 149
 
PROCEDURAL POSTURE: Appellees, a married couple, obtained an injunction in the Circuit Court of the United States for the Western District of Kentucky to compel appellant railroad company to issue travel passes to appellees according to a contract.

FACTS:
-Appellant, a railroad company, entered into a contract with appellees, a married couple, to give them travel passes every year.
-When a new federal law prohibited railroads from issuing free passes, appellant declined to renew the passes.
-Appellees sued in federal court for specific performance of the contract, and the circuit court granted an injunction.

HOLDING:
The Supreme Court of the United States, finding it improper to plead that a defense under federal law was anticipated, reversed the judgment and remanded to the circuit court with instructions to dismiss the action for lack of federal question jurisdiction.

RULES:
The complainant in the first instance shall be confined to a statement of its cause of action, leaving to the defendant to set up in his answer what his defense is, and if anything more than a denial of complainant's cause of action, imposing upon the defendant the burden of proving such defense.

OUTCOME: The Supreme Court of the United States reversed the judgment and remanded to the circuit court with instructions to dismiss the action for lack of federal question jurisdiction.
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