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Louisville & Nashville Railroad v. Mottley

United States Supreme Court
211 U.S. 149 (1908)


 

Facts

In 1871, the Mottleys (plaintiffs) were injured in a railway accident. The railroad, Louisville & Nashville Railroad (defendant), settled the Mottleys’ claims with a lifetime pass for free transportation on its line. In 1906, Congress passed an act forbidding passes granting free transportation. In 1907, the railroad refused to renew the Mottleys' passes. The Mottleys brought suit in federal district court, seeking specific performance of their settlement agreement with the railroad. The Mottleys alleged that the act did not apply to their free pass and that, if the law is construed as prohibiting such passes, it deprives them of their property in violation of the Fifth Amendment. The railroad demurred to the Mottley’s complaint. The trial court overruled the demurrer and entered judgment in favor of the Mottleys. The railroad appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Moody, J.)

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Questions & Answers


How is the "arising under" interpretation in Section 1331 different from "arising under" in Article III of the Constitution?

As I was reading the "Notes and Problems" section in my book following the court's opinion, the authors said that the phrase "arising under" means different things in the Constitution and in the statute. In particular, they said the Supreme Court has found the phrase in the Constitution to be broader than in the statute and that it was under this broader interpretation that the Court had jurisdiction to hear and decide Mottley the second time around after they re-filed their case in state court even though the district court did not have jurisdiction under the narrower statutory definition the first time.

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