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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, E.L. and Annie Mottley (plaintiffs) were injured in a railway accident while passengers on the Louisville & Nashville Railroad (the railroad) (defendant). The railroad settled the Mottleys’ injury claims by giving the couple a lifetime pass for free transportation on its line. In 1906, Congress 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 all from Kentucky and, therefore, diverse citizenship did not exist. Instead, the Mottleys asserted federal-question jurisdiction, with their complaint alleging two federal issues: (1) whether the new federal statute applied to the Mottleys’ passes and (2) if so, whether the new federal 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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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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