Railroad Commission v. Pullman Co.

Last updated

Railroad Commission v. Pullman Co.
Seal of the United States Supreme Court.svg
Argued February 4, 1941
Decided March 3, 1941
Full case nameRailroad Commission of Texas, et al. v. Pullman Company, et al.
Citations312 U.S. 496 ( more )
61 S. Ct. 643; 85 L. Ed. 971; 1941 U.S. LEXIS 1102
Case history
PriorAppeal from the District Court of the United States for the Western District of Texas
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
Harlan F. Stone  · Owen Roberts
Hugo Black  · Stanley F. Reed
Felix Frankfurter  · William O. Douglas
Frank Murphy
Case opinion
MajorityFrankfurter, 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 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. [1]

Contents

This form of abstention allows state courts to correct things like equal protection 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, an administrative agency in Texas issued an order requiring sleeping cars on trains to be staffed by conductors (who were white) instead of by porters (who were black). The railroad and the Pullman Company, as well as the Brotherhood of Sleeping Car Porters, sued, alleging a violation of Fourteenth Amendment equal protection. 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 United States Supreme Court, this case presented an opportunity for the Court to discuss whether it was appropriate for the United States District Court 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.

Later developments

Through a number of later decisions, courts clarified that in order for Pullman abstention to be invoked, three conditions must be apparent:

  1. The case presents both state grounds and federal constitutional grounds for relief;
  2. The proper resolution of the state ground for the decision is unclear; and
  3. 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

Related Research Articles

Separate but equal was a legal doctrine in United States constitutional law, according to which racial segregation did not necessarily violate the Fourteenth Amendment to the United States Constitution, which nominally guaranteed "equal protection" under the law to all people. Under the doctrine, as long as the facilities provided to each race were equal, state and local governments could require that services, facilities, public accommodations, housing, medical care, education, employment, and transportation be segregated by race, which was already the case throughout the states of the former Confederacy. The phrase was derived from a Louisiana law of 1890, although the law actually used the phrase "equal but separate".

An administrative law judge (ALJ) in the United States is a judge and trier of fact who both presides over trials and adjudicates claims or disputes involving administrative law. ALJs can administer oaths, take testimony, rule on questions of evidence, and make factual and legal determinations.

<span class="mw-page-title-main">Abstention doctrine</span> Doctrine prevalent in the American judiciary

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.

Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), was a landmark U.S. Supreme Court decision in which the Court held that the United States does not have a general federal common law and that U.S. federal courts must apply state law, not federal law, to lawsuits between parties from different states that do not involve federal questions. In reaching this holding, the Court overturned almost a century of federal civil procedure case law, and established the foundation of the modern law of diversity jurisdiction.

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.

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 set forth in Railroad Commission v. Pullman Co., 312 U.S. 496 (1941).

<span class="mw-page-title-main">Railroad Commission of Texas</span> State energy regulatory agency in Texas, USA

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.

United States v. Darby Lumber Co., 312 U.S. 100 (1941), was a case in which the United States Supreme Court upheld the Fair Labor Standards Act of 1938, holding that the U.S. Congress had the power under the Commerce Clause to regulate employment conditions. The unanimous decision of the Court in this case overturned Hammer v. Dagenhart, 247 U.S. 251 (1918), limited the application of Carter v. Carter Coal Company, 298 U.S. 238 (1936), and confirmed the underlying legality of minimum wages held in West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937).

Burford v. Sun Oil Co., 319 U.S. 315 (1943), was a United States Supreme Court case in which the Court created a new doctrine of abstention.

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.

Commodity Futures Trading Commission v. Schor, 478 U.S. 833 (1986), was a case in which the Supreme Court of the United States held an administrative agency may, in some cases, exert jurisdiction over state-law counterclaims.

Henderson v. United States, 339 U.S. 816 (1950), was a landmark United States Supreme Court decision in the jurisprudence of the United States that abolished segregation in railroad dining cars with an 8-0 ruling.

<span class="mw-page-title-main">Jerry Edwin Smith</span> American judge

Jerry Edwin Smith is an American attorney and jurist serving as a United States circuit judge of the United States Court of Appeals for the Fifth Circuit.

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.

Harrison v. NAACP, 360 U.S. 167 (1959), is a 6-to-3 ruling by the Supreme Court of the United States which held that the United States District Court for the Eastern District of Virginia should have abstained from deciding the constitutionality of three barratry, champerty, and maintenance laws in the state of Virginia until state courts had had a reasonable chance to construe them.

<span class="mw-page-title-main">Anti-Injunction Act</span> US federal statute (28 U.S.C. § 2283)

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:

United Gas Pipe Line Co. v. Mobile Gas Service Corp., 350 U.S. 332 (1956), is a United States Supreme Court case in which the Court interpreted the Natural Gas Act of 1938 (NGA) as not allowing a gas supply company to unilaterally modify rates in a natural gas supply contract by filing a new rate schedule with the Federal Power Commission (FPC). Mobile Gas and its companion case Federal Power Commission v. Sierra Pacific Power Co. established the Mobile-Sierra presumption which holds that an electricity or natural gas supply rate established resulting from a freely negotiated contract is presumed to be "just and reasonable" and thus acceptable under the NGA or Federal Power Act (FPA).

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.

Securities and Exchange Commission v. Jarkesy is a case pending before the Supreme Court of the United States. In May 2022, Court of Appeals for the Fifth Circuit held, under certain statutory provisions, the Securities and Exchanges Commission's administrative adjudication of fraud claims without jury trials in their administrative proceedings with their own administrative law judges (ALJs) violated three provisions of the Constitution.

References

  1. Railroad Commission v. Pullman Co., 312 U.S. 496 (1941).
  2. Government and Civil Employees Organizing Committee, CIO v. Windsor, 353 U.S. 364 (1957).
  3. England v. Louisiana State Board of Medical Examiners , 375 U.S. 411 (1964).