Thurston Motor Lines, Inc. v. Jordan K. Rand, Ltd.

This is a simple contract-collection action which normally would have been brought in state court. Thurston Motor Lines seeks to recover $661.41 in motor freight charges that Jordan K. Rand, Ltd. allegedly promised to pay. Thurston Motor sued in federal court solely because the charges agreed upon in the shipping contract complied with the rate and tariff provisions of the Interstate Commerce Act, 49 U.S.C. §§ 10701-10786 . The district court held that this tangential relationship to federal law cannot support federal-question jurisdiction under 28 U.S.C. § 1337 . We agree.

I

The precise limits of federal-question jurisdiction are uncertain. See, e.g., Town of Greenhorn v. Baker County, 596 F.2d 349, 351 (9th Cir. 1979). We have, however, recognized two requirements: “plaintiffs must show that the federal question was ‘well-pleaded’ and that the claim arose ‘directly’ under federal law.” Id., citing League to Save Lake Tahoe v. B. J. K. Corp., 547 F.2d 1072, 1074 (9th Cir. 1976).

“Under the ‘well-pleaded complaint’ requirement, federal jurisdiction exists only where the plaintiff would be required to plead and prove a proposition of federal law to win a default judgment.”…