Facts
The plaintiffs were chiropractors in the state of Louisiana. They sued in the United States District Court to prevent state officials from applying a licensing scheme to them, arguing both that they were not within the group to whom the statute applied, and that the statute infringed the Fourteenth Amendment to the United States Constitution. The District Court noted that a state court might find that the state law did not apply to the plaintiffs, and abstained from hearing the case pursuant to the Pullman abstention doctrine.
The plaintiffs noted that a case refining Pullman called Government and Civil Employees Organizing Committee, CIO v. Windsor , 353 U.S. 364 (1957) had held that the judgment of the state court was meaningless unless the state court was aware that constitutional questions had also been raised as to the validity of the statute. The plaintiffs therefore brought both claims in the Louisiana state court (as they believed Pullman and Windsor required). The state court found against them on both statutory and constitutional claims.
The plaintiffs then returned to the District Court seeking a new hearing on the constitutional question. The defendant then sought a dismissal on res judicata grounds, contending that the decision of the state court was binding as to the constitutional issue.
Result
The Supreme Court, in an opinion by Justice Brennan, noted that the state court determination would indeed bind the federal court. The proper procedure, the Court determined, is to give notice that the federal issue is contended, but to expressly reserve the claim on the federal issue for the federal court. If such a reservation is made, the parties can return to the federal court, even if the state court makes a ruling on the issue.
However, the Court also noted that even if the parties did not expressly reserve the federal issues, they can still return to the federal court if it is apparent that the parties had avoided adjudication of the federal law issues.
Because the plaintiffs in this case believed that they were just following the law as required, they would not be barred from continuing in the federal court.
In law, standing or locus standi is a condition that a party seeking a legal remedy must show they have, by demonstrating to the court, sufficient connection to and harm from the law or action challenged to support that party's participation in the case. A party has standing in the following situations:
In law, the terms moot and mootness have different meanings in British English and American English.
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.
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.
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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.
Ashwander v. Tennessee Valley Authority, 297 U.S. 288 (1936), was a United States Supreme Court case that provided the first elaboration of the doctrine of "Constitutional avoidance".
The law of the United States comprises many levels of codified and uncodified forms of law, of which the most important is the United States Constitution, which prescribes the foundation of the federal government of the United States, as well as various civil liberties. The Constitution sets out the boundaries of federal law, which consists of Acts of Congress, treaties ratified by the Senate, regulations promulgated by the executive branch, and case law originating from the federal judiciary. The United States Code is the official compilation and codification of general and permanent federal statutory law.
The Supremacy Clause of the Constitution of the United States, establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thus take priority over any conflicting state laws. It provides that state courts are bound by, and state constitutions subordinate to, the supreme law. However, federal statutes and treaties are supreme only if they do not contravene the Constitution.
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:
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