''Railroad Commission v. Pullman Co.'', 312 U.S. 496 (1941), was a case in which the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point ...

determined that it was appropriate for

United States federal courts The federal judiciary of the United States is one of the three branches of the federal government of the United States organized under the United States Constitution and laws of the federal government. The U.S. federal judiciary consists primaril ...

to abstain from hearing a case in order to allow state courts to decide substantial

Constitutional A constitution is the aggregate of fundamental principles or established precedents that constitute the legal basis of a polity, organisation or other type of entity and commonly determine how that entity is to be governed. When these princip ...

issues that touch upon sensitive areas of state social policy. This form of abstention allows state courts to correct things like

equal protection The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "''nor shall any State ... deny to any person within its jurisdiction the equa ...

violations for themselves, thus avoiding the embarrassment of having state policy corrected by the federal courts. Under Pullman abstention, the federal court retains jurisdiction to hear the case if the state court's resolution is still constitutionally suspect.

Facts

The

Railroad Commission of Texas The Railroad Commission of Texas (RRC; also sometimes called the Texas Railroad Commission, TRC) is the state agency that regulates the oil and gas industry, gas utilities, pipeline safety, safety in the liquefied petroleum gas industry, and sur ...

, an administrative agency in

Texas Texas (, ; Spanish language, Spanish: ''Texas'', ''Tejas'') is a state in the South Central United States, South Central region of the United States. At 268,596 square miles (695,662 km2), and with more than 29.1 million residents in 2 ...

issued an order requiring sleeping cars on

trains In rail transport, a train (from Old French , from Latin , "to pull, to draw") is a series of connected vehicles that run along a railway track and transport people or freight. Trains are typically pulled or pushed by locomotives (often k ...

to be staffed by conductors (who were white) instead of by porters (who were black). The railroad and the

Pullman Company The Pullman Company, founded by George Pullman, was a manufacturer of railroad cars in the mid-to-late 19th century through the first half of the 20th century, during the boom of railroads in the United States. Through rapid late-19th century ...

, as well as the Brotherhood of Sleeping Car Porters, sued, alleging a violation of Fourteenth Amendment

. The case was initially considered by a three-judge panel of one Circuit Court judge and two local District Court judges, who held that the agency action violated the law of Texas. The case was appealed directly to the Supreme Court.

Issue

Although the parties did not raise the issue before the

, this case presented an opportunity for the Court to discuss whether it was appropriate for the

United States District Court The United States district courts are the trial courts of the U.S. federal judiciary. There is one district court for each federal judicial district, which each cover one U.S. state or, in some cases, a portion of a state. Each district c ...

to grant relief, when the suit could have been brought in a state court in Texas.

Result

The Supreme Court, in an opinion by Justice Frankfurter, noted that there are a number of reasons that this case should not be heard by a federal court. *Although federal courts may often be called upon to interpret the law of a state, they are really just guessing at the conclusions a state court would arrive at when confronted by the same question. *Furthermore, although this case presents a substantial constitutional issue, federal courts must not get into sensitive area of state social policy unless they have to. Therefore, the court concluded that the issue should be sent back to the state courts to see if the state courts can find some reason that the administrative order is invalid under state law.

Later developments

Through a number of later decisions, courts clarified that in order for ''Pullman'' abstention to be invoked, three conditions must be apparent: # The case presents both state grounds and federal constitutional grounds for relief; # The proper resolution of the state ground for the decision is unclear; and # The disposition of the state ground could obviate adjudication of the federal constitutional ground. The mechanics of employing the doctrine were refined in ''Government and Civil Employees Organizing Committee, CIO v. Windsor'', and ''

England v. Louisiana State Board of Medical Examiners ''England v. Louisiana State Board of Medical Examiners'', 375 U.S. 411 (1964), was a United States Supreme Court decision that refined the procedures for U.S. federal courts to abstain from deciding issues of state law, pursuant to the doctrine ...

''.. The first case held that when the issue is brought before the state court, the parties must inform the state court that a federal constitutional claim is involved—otherwise, the state court might not take that into account when interpreting the law of the state. The second case held that the parties could nonetheless reserve the right to have the federal constitutional claim adjudicated in the federal court.

References

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