Facts
The Railroad Commission of Texas granted defendant Burford an order which gave him a right to drill four oil wells on a small plot of land on the East Texas Oil Field. Plaintiff Sun Oil Co. sued Burford in United States District Court for the Western District of Texas, asserting both federal question jurisdiction and diversity jurisdiction, and alleging that the commission's order denied them Due Process of law under the Fourteenth Amendment.
The commission was charged by Texas state law with the administration of oil and gas regulations, including production quotas for each field and well. Quotas were set in conjunction with other oil- and gas-producing states. Part of its duties was regulating the spacing of the individual oil wells. Because of the complex geology of oil fields and multiple division of surface rights, one user's oil drilling activity can affect the production of others, which meant that both public and private interests were at stake. Underground water and gas pressure needed to be monitored in order to maintain steady oil production and prevent waste.
Because the rule governing the spacing of wells over the oil field, known as "Rule 37", generated a large amount of litigation among many competing landowners and potential drillers, the Texas Legislature had developed a special system of judicial review for such cases. Commission orders could be appealed to the state district court in Travis County, Texas, and could then be reviewed by the Texas Court of Civil Appeals, and then to the Texas Supreme Court, which had final authority over questions of state law.
The district court of Travis County was given exclusive jurisdiction over appeals of Commission orders, allowing them to specialize in such matters and promoting cooperation between the court and the commission. There already existed conflicting statutory interpretations between the state and federal courts in this matter, so the district court chose to abstain in deference to the state and dismiss the case. The United States Court of Appeals for the Fifth Circuit reversed the District Court's dismissal.
Concurrence
Justice Douglas, concurring, implied that the Court's ruling did not go far enough. He noted that
the opinion of the Court as I read it does not hold or even fairly imply that 'the enforcement of state rights created by state legislation and affecting state policies is limited to the state courts.' Any such holding would result in a drastic inroad on diversity jurisdiction-a limitation which I agree might be desirable but which Congress, not this Court, should make. The holding in these cases, however, goes to no such length.
319 U.S. at 335.
Here, he is essentially criticizing the reach of the federal courts' diversity jurisdiction into matters of state law. He pointed out that even though the Court's opinion views the Commission and the Texas court system "working partners" in administering the law, the courts are in reality sitting in judgment of the commission's decisions. This is a role which a U.S. District Court would be unwise to play, for it would interfere with the State's administration of its own laws and create serious issues of federalism and create conflicting legal precedent.
In the United States, a state supreme court is the highest court in the state judiciary of a U.S. state. On matters of state law, the judgment of a state supreme court is considered final and binding in both state and federal courts.
In the United States, a state court has jurisdiction over disputes with some connection to a U.S. state. State courts handle the vast majority of civil and criminal cases in the United States; the United States federal courts are far smaller in terms of both personnel and caseload, and handle different types of cases.
In law, certiorari is a court process to seek judicial review of a decision of a lower court or government agency. Certiorari comes from the name of an English prerogative writ, issued by a superior court to direct that the record of the lower court be sent to the superior court for review. The term is Latin for "to be made certain", and comes from the opening line of such writs, which traditionally began with the Latin words "Certiorari volumus...".
An abstention doctrine is any of several doctrines that a United States court may apply to refuse to hear a case if hearing the case would potentially intrude upon the powers of another court. Such doctrines are usually invoked where lawsuits involving the same issues are brought in two different court systems at the same time.
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 primarily of the U.S. Supreme Court, the U.S. Courts of Appeals, and the U.S. District Courts. It also includes a variety of other lesser federal tribunals.
An advisory opinion is an opinion issued by a court or a commission like an election commission that does not have the effect of adjudicating a specific legal case, but merely advises on the constitutionality or interpretation of a law. Some countries have procedures by which the executive or legislative branches may certify important questions to the judiciary and obtain an advisory opinion. In other countries or specific jurisdictions, courts may be prohibited from issuing advisory opinions.
The Erie doctrine is a fundamental legal doctrine of civil procedure in the United States which mandates that a federal court called upon to resolve a dispute not directly implicating a federal question must apply state substantive law.
Railroad Commission v. Pullman Co., 312 U.S. 496 (1941), was a case in which the United States Supreme Court determined that it was appropriate for United States federal courts to abstain from hearing a case in order to allow state courts to decide substantial Constitutional issues that touch upon sensitive areas of state social policy.
Louisville & Nashville Railroad Company v. Mottley, 211 U.S. 149 (1908), was a United States Supreme Court decision that held that under the existing statutory scheme, federal question jurisdiction could not be predicated on a plaintiff's anticipation that the defendant would raise a federal statute as a defense. Instead, such jurisdiction can only arise from a complaint by the plaintiff that the defendant has directly violated some provision of the Constitution, laws, or treaties of the United States. This reading of the federal question jurisdiction statute is now known as the well-pleaded complaint rule.
The Railroad Commission of Texas is the state agency that regulates the oil and gas industry, gas utilities, pipeline safety, safety in the liquefied petroleum gas industry, and surface coal and uranium mining. Despite its name, it ceased regulating railroads in 2005, when the last of the rail functions were transferred to the Texas Department of Transportation.
In the United States, removal jurisdiction allows a defendant to move a civil action filed in a state court to the United States district court in the federal judicial district in which the state court is located. A federal statute governs removal.
Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976), was a case in which the Supreme Court of the United States extensively refined the abstention doctrine to prevent duplicative litigation between state and federal courts.
In law, intervention is a procedure to allow a nonparty, called intervenor to join ongoing litigation, either as a matter of right or at the discretion of the court, without the permission of the original litigants. The basic rationale for intervention is that a judgment in a particular case may affect the rights of nonparties, who ideally should have the right to be heard.
In Constitutional law, the Last Resort Rule is a largely prudential rule which gives a federal court the power to avoid a constitutional issue in some circumstances. This rule dictates that, even if all other jurisdictional and justiciability obstacles are surmounted, federal courts still must avoid a constitutional issue if there is any other ground upon which to render a final judgment. The last resort rule can function as a distinct barrier to Constitutional avoidance. It is articulated by Justice Brandeis in Ashwander v. Tennessee Valley Authority.
In the law of the United States, a certified question is a formal request by one court from another court, usually but not always in another jurisdiction, for an opinion on a question of law.
Moses H. Cone Memorial Hospital v. Mercury Construction Corp., 460 U.S. 1 (1983), commonly cited as Moses Cone or Cone Hospital, is a United States Supreme Court decision concerning civil procedure, specifically the abstention doctrine, as it applies to enforcing an arbitration clause in a diversity case. By a 6–3 margin, the justices resolved a complicated construction dispute by ruling that a North Carolina hospital had to arbitrate a claim against the Alabama-based company it had hired to build a new wing, even though it meant that it could not consolidate it with ongoing litigation it had brought in state court against the contractor and architect.
The Anti-Injunction Act, is a United States federal statute that restricts a federal court's authority to issue an injunction against ongoing state court proceedings, subject to three enumerated exceptions. It states:
In law, an appeal is the process in which cases are reviewed by a higher authority, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of clarifying and interpreting law. Although appellate courts have existed for thousands of years, common law countries did not incorporate an affirmative right to appeal into their jurisprudence until the 19th century.
United Gas Pipe Line Co. v. Ideal Cement Co., 369 U.S. 134 (1962), is a United States Supreme Court case which vacated a lower appellate court decision, holding that federal courts should abstain from ruling on the constitutionality of a state tax issue that state courts should determine.
Louisiana Power & Light Co. v. City of Thibodaux, 360 U.S. 25 (1959), was a case in which the Supreme Court created a new doctrine of abstention.
