Well-pleaded Complaint Rule and § 1331
Louisville & Nat’l RR v. Motley
- Under Judiciary Act, now § 1331, federal question must arise out of original cause of action (i.e. be in claim, not in response).
- If Пs can't bring suit, Δs may not bring defensive action for declaratory relief in federal court either.
- Allows for determination of jurisdiction based on pleadings
- Conserves judicial resources.
- On the other hand...
- Federal courts are better able to handle questions of federal law, regardless of when they arise.
- Пs given lifetime pass by Δ after accident. Law passed outlawing passes to curtail corruption. Пs sue Δ fpr breach of K and assert in claim that violates Due Process not to honor passes.
- SCOTUS decides sua sponte that П;s action does not "arise under."
- The claim just anticipated a defense.