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Louisville & Nashville Railroad v. Mottley

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

Written by DeAnna Swearingen, LLM

Facts

In 1871, Erasmus and Annie Mottley (plaintiffs) were injured in a railway accident. The Mottleys asserted claims against Louisville & Nashville Railroad (the railroad) (defendant) for their injuries, and the railroad settled those claims by giving the Mottleys a lifetime pass for free transportation on its line. Decades later, Congress became concerned that railroads were using free passes to bribe public officials and passed a statute forbidding free railroad passes entirely. The next year, the railroad refused to renew the Mottleys’ free passes. The Mottleys sued the railroad in federal district court, alleging a state-law breach-of-contract claim. The parties were not diverse, but the Mottleys asserted that the federal court had subject-matter jurisdiction through federal-question jurisdiction. Specifically, the Mottleys’ complaint alleged that (1) the new federal statute did not apply to their free passes and (2) if the new statute was not a defense for the railroad because the new statute did apply to their passes, the statute was an unconstitutional taking that violated the Fifth Amendment. The trial court entered judgment for the Mottleys. The railroad appealed to the United States Supreme Court.

Rule of Law

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Issue

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Holding and Reasoning (Moody, J.)

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The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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