Louisville & Nashville RR v Mottley
Relevant Facts: The Mottleys were injured in a railway accident. To settle their claims, the RR gave them a lifetime pass good for free transportation on the line. Some time later Congress made that practice illegal to stymie bribes to public official with the passes. The RR thereafter refused to honor the Mottleys’ passes under the new legislation. Legal Issue(s): Whether that part of the Act of Congress which makes it illegal to perform a contract for transportation, who before the passage of the Act, had accepted the same in satisfaction of a valid cause of action against the RR; and whether the Act is in violation of the 5th Amendment’s DP Clause? Court’s Holding: Not necessary to consider; ct is w/o jurisdiction. Procedure: APPEAL from U.S. Circuit Court granting Mottleys’ specific performance. Reversed and remanded with instructions to dismiss the suit for want of jurisdiction. Law or Rule(s): A Pl shall be confined to a statement of its cause of action, leaving the Df to set up in his answer what his defense is and, if anything more than a denial of Pl’s cause of action. Court Rationale: A suit arises under the Constitution and laws of the United States ONLY when the Pl’s statement of his own cause of action shows that it is based upon those laws or the Constitution. The Pl’s original cause of action must arise under the Constitution or the laws/treaties of the U.S., not the DF’s defenses. A suggestion of one party, that the other will or may set up a claim under the Constitution or laws of the U.S., does not make the suit one arising under that Constitution or those laws. The ONLY way in which it might be claimed that a Fed Q was presented would be in the Pl’s complaint/statement of what the defense of Dfs would be and Pl’s answer to such a defense, not where the Pl’s cause of action is based upon the Dfs defense and answer that defense before the Df has answered or plead. Plaintiff’s Argument: The Df and Pl had a contract for transportation which was made illegal by the Act of Congress, which is in violation of the 5th Amendment. Defendant’s Argument: The Act of Congress made the contract illegal and Df can not be bound to an illegal contract by way of legislation of Federal law.
Merrell Dow Pharmaceuticals, Inc v. Thompson
Facts: Ps, husband and wife, brought action against D, a pharmaceutical company. Ps alleged that their children suffered birth defects because the wife took drug manufactured by D. Ps brought claim based on negligence, breach of warranty, strict liability and fraud. Ps also claimed that D violated FDCA. D removed the action to federal court based on federal question jurisdiction. Ps claimed that the removal was improper and moved to remand the case back to state court. I Because the part about the FDCA was only one part of the complaint and not essential to find the (D) negligent this is not have to be aa federal case. They ruled that because of this it is not about federal law or the cause of action did not fall under federal law. II The complaint would need to have a resolution under federal law of a substantial question. III (D) 3 Arguments: 1 – believes that federal question jurisdiction is appropriate where there is a federal question. They court says that just because there is a the presence of a federal question does not automatically move the court. 2 – says that there is powerful federal interest in attaining uniform judgments on federal questions. Court says says they disagree because they still retain the power to review. 3 – there is special federal questions in this case.
Procedure: Trial court denied Ps’ motion to remand back to state court and the sixth circuit reversed. Issue: Was there sufficient federal question jurisdiction for the federal court to hear the case [there was no diversity jurisdiction]? Holding: No Rationale: The Congress never intended to create a private cause of action under FDCA. The fact that there may be a violation of FDCA by D does not give Ps the private federal cause of action under this statute. Therefore, the removal from the state court was improper and the federal court did not have subject matter jurisdiction. Notes: Federal courts are courts of limited jurisdiction. Federal courts can have subject matter jurisdiction over cases either by diversity of jurisdiction route or by federal question route. This case dealt with federal question jurisdiction. This case rules that the
mere fact that there may be a violation of some federal law, when congress didn’t intend to create private cause of action under that law, does not establish federal question jrx.