American Well Works Co. v. Layne & Bowler Co.

American (plaintiff) sued Layne (defendant) in state court, alleging Layne falsely told American's customers that American's pump infringed Layne's patent and threatened or filed suits against those customers to damage American's business; Layne removed the case to federal court on the theory that the dispute necessarily arose under federal patent law, and the district court dismissed for lack of jurisdiction on that same theory.