The Louisville & Nashville Railroad v. Mottley: A Landmark in Federal Jurisdiction and the Limits of Artful Pleading
The early twentieth century witnessed a dramatic expansion of federal regulatory power over American commerce, particularly in transportation. But mottley*, 219 U. S. Against this backdrop of evolving law and litigation, *Louisville & Nashville Railroad v. At the heart of this transformation stood the Interstate Commerce Act of 1887, the first major federal statute designed to regulate railroad rates and practices. Day to day, 421 (1911), emerged as a important decision that reshaped the boundaries of federal question jurisdiction. The case continues to be cited in law schools and courtrooms as a definitive illustration of the "well-pleaded complaint rule" and the doctrine of complete preemption.
The Historical Context and Facts of the Case
To understand Mottley, one must first appreciate the legal landscape of the time. Like many carriers, L&N published rate schedules subject to approval and oversight by the Interstate Commerce Commission (ICC), the federal body created to enforce the Interstate Commerce Act. Think about it: the Louisville & Nashville Railroad (L&N) operated extensive lines across Kentucky, Tennessee, and the surrounding states. These rates were not merely contractual promises; they were regulatory mandates carrying the force of federal law.
The dispute originated when Mottley, a shipper and business owner, filed a lawsuit in a Kentucky state court against the railroad. Mottley’s complaint alleged that the railroad had breached a private contract by charging freight rates that exceeded those agreed upon in a prior arrangement. In essence
