Reference Check

1774.713 - 1795.904 Will Bode

I'm not sure it's right, because in 1875, when the federal jurisdiction statute was created, its stated purpose was to expand federal question jurisdiction to the maximum permitted by the Constitution. And I'm not convinced that the test turns on who created the cause of action because in 1875, it was like the pre-Erie world where we didn't think about causes of action the same way we do now.