Railroad Commission v. Pullman Co.
Railroad Commission v. Pullman Co. | |
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Case history | |
Prior | Appeal from the District Court of the United States for the Western District of Texas |
Court membership | |
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Case opinion | |
Majority | Frankfurter, joined by Hughes, McReynolds, Stone, Black, Reed, Douglas, Murphy |
Roberts took no part in the consideration or decision of the case. |
Railroad Commission v. Pullman Co., 312 U.S. 496 (1941), was a case in which the
This form of abstention allows state courts to correct things like
Facts
The
Issue
Although the parties did not raise the issue before the
Result
The Supreme Court, in an opinion by
- 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,[2] and England v. Louisiana State Board of Medical Examiners.[3] 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.
See also
References
External links
- Works related to Railroad Commission of Texas v. Pullman Company at Wikisource
- Text of Railroad Comm'n v. Pullman Co., 312 U.S. 496 (1941) is available from: CourtListener Justia Library of Congress