## Facts

- Wilford P. Joy brought an ejectment action in federal circuit court against the City of St. Louis and a private company to recover riverfront land.
- Joy alleged title traced to a 1799 Spanish concession to Louis Labeaume, later confirmed in fee by an 1812 federal statute.
- Joy further alleged the United States issued a patent (1852) and later statutes (including 1874 legislation) released remaining federal interests to the equitable owners.
- The disputed property consisted chiefly of accreted land along the Mississippi River in front of the original tract.
- The federal circuit court dismissed solely for lack of subject-matter jurisdiction; Joy sought Supreme Court review under the Evarts Act.

## Issues

1. Whether, absent diversity, an ejectment complaint “arises under” federal law when the plaintiff’s chain of title includes federal confirmation statutes and a federal patent.
2. Whether federal-question jurisdiction can rest on an anticipated federal defense rather than on the plaintiff’s own statement of claim.
3. Whether disputes about whether the original tract reached the river and whether the owner takes accretions present federal questions or instead matters of local property law.

## Decision

- The Supreme Court affirmed the dismissal for lack of jurisdiction.
- The Court held the complaint did not state a case arising under the Constitution or laws of the United States.
- The federal source of Joy’s title did not create jurisdiction because the case did not necessarily require construction of any federal statute or patent.
- The controlling questions—extent of the original tract to the river and entitlement to accretions—were treated as factual and local-law matters.
- The Court noted that if federal rights are specially set up and denied in state court, Supreme Court review may later be available through the statutory route for review of federal questions decided by state courts.

## Legal Principles

- Federal-question jurisdiction must appear from the plaintiff’s own statement of claim; it cannot be created by alleging that a defense will raise a federal issue.
- The mere fact that title derives from a federal patent or act of Congress does not establish a federal question; jurisdiction requires an actual dispute over construction of the federal instrument.
- Federal courts independently construe federal grants, but the incidents of ownership of federally conveyed land bordering navigable waters (including riparian rights and accretion) are generally determined by the law of the state where the land lies, so long as state rules do not impair the efficacy of the federal grant.
- Whether a patented tract reaches a river under the distances called for may be a question of fact; whether accretions belong to the riparian owner is ordinarily a question of local law.
- An ejectment action for accreted land, without diversity, is not maintainable in federal court as arising under federal law when it turns on local property law rather than construction of federal statutes or patents.

## Conclusion

The Court held that an ejectment claim for Mississippi River accretions did not arise under federal law merely because the plaintiff traced title to federal confirmations and patents; without a genuine dispute over construction of federal instruments, the controversy belonged in state court, with Supreme Court review available only if a specific federal right is later raised and denied.


Joy v. City of St. Louis, 201 U.S. 332 (1906)