Civil Procedure I, Pages 210–212

Louisville & Nashville Railroad v. Mottley

Supreme Court of the United States, 1908

Facts:

Defendant gave plaintiffs lifetime tickets as compensation for injuries sustained on defendant's railroad. Congress outlawed free tickets because they were being used for bribery. Defendant deactivated plaintiffs' free tickets. Plaintiffs sued in federal court.

Procedural History:

Federal trial court overruled defendant's demurrer.

Issue:

Whether the circuit court had jurisdiction

Plaintiff's Argument:

Defendant's refusal to honor plaintiffs' tickets in against the spirit of the law. If it doesn't, the law is unconstitutional.

Reasoning:

For the circuit court to have jurisdiction for this case, plaintiff would have to anticipate defendant's defenses ahead of time.

Judgment:

Reversed and remitted with instruction to dismiss for want of jurisdiction.

Rule/Holding:

Circuit courts cannot hear anticipated defense that were not part of a "well-pleaded complaint."