Appellant
Railroad Commission of Texas, et al.
Appellee
Pullman Company, et al.
Appellant's Claim
That under Texas law it had authority to regulate Pullman sleepers, and thata federal district court erred in preventing enforcement of this regulation.
Chief Lawyers for Appellant
Cecil A. Morgan, Cecil C. Rotsch
Chief Lawyer for Appellee
Ireland Graves
Justices for the Court
Hugo Lafayette Black, William O. Douglas, Felix Frankfurter (writing for theCourt), Charles Evans Hughes, James Clark McReynolds, Frank Murphy, Stanley Forman Reed, Harlan Fiske Stone
Justices Dissenting
None (Owen Josephus Roberts did not participate)
Place
Washington, D.C.
Date of Decision
3 March 1941
Decision
Reversed the lower court's order to enjoin enforcement of the regulation anddirected the case be heard in the state courts.
Significance
The Pullman decision clearly articulated for the first time the Supreme Court's "abstention doctrine." This doctrine defines when a federal court may choose not to exercise its jurisdiction, even though a constitutional issue exists, to first let a state court try to resolve the question. As used inPullman, the abstention doctrine frees the states from having the federal government unnecessarily involved in their affairs.
The Supreme Court has often limited the cases it hears, based on its interpretation of Article III of the Constitution, which established the Court. At times, acts of Congress, such as the Judiciary Acts of 1789 and 1875, have alsolimited or expanded the Court's jurisdiction. For many years, however, the Court seemed to follow the words of Chief Justice John Marshall: "It is most true, that this Court will not take jurisdiction if it should not: but it is equally true, that it must take jurisdiction if it should . . . We have no more right to decline the exercise of jurisdiction which is given, than to usurpthat which is not given."
But Marshall's view was not absolute. In the 1930s, the Court heard a numberof cases in which it could have ruled, but chose not to, or ordered other federal courts to defer to the state courts. This idea of abstaining from jurisdiction was first clearly stated in Railroad Commission of Texas v. PullmanCompany, and is sometimes called the Pullman abstention doctrine.
After the Civil War, George Pullman invented the luxury railroad sleeping carand helped revolutionize transcontinental travel in America. In the 1940s, the Pullman Company was still a major force in train travel. When the Texas Railroad Commission issued an order that affected staffing on Pullman sleepers,the company, along with the railroad lines, took the matter to court.
Race, Economics, and State Law
On the less populated stretches of Texas, railroads usually equipped their trains with just one Pullman car. When a train had just one Pullman, the car was under the control of a porter, who reported to the train conductor. Trainswith more than one Pullman had their own Pullman conductor. At the time, theporters were all African American; the Pullman conductors were all white. TheTexas Railroad Commission issued an order requiring all trains traveling through Texas to have a Pullman conductor in charge of all sleeping cars.
The order was generally interpreted as racially based, as it would provide jobs for more white conductors in Texas. The order may have also been an attempt to deprive the black porters of any authority on the trains. In any event,the Pullman Company and the railroads filed suit in federal district court, seeking to enjoin the order. The companies argued that the order was not authorized under Texas law and violated their due process and equal protection rights, as defined in the Fourteenth Amendment. The Pullman porters also joinedthe suit, claiming the commission's order violated the Fourteenth Amendment by discriminating against blacks.
The district court found it had jurisdiction on the matter and said Texas lawdid not give the commission authority to issue the order. The court forbadethe order from taking effect. The Texas Railroad Commission then appealed tothe Supreme Court. In a 7-0 ruling, the Court said the district court shouldhave abstained from deciding this case and let the state courts decide the issue. The Court reversed the lower court's ruling and, while acknowledging thedistrict court's jurisdiction, ordered the matter to be heard in the state courts.
In his decision, Justice Frankfurter admitted the case brought up meaningfulconstitutional issues. But the constitutional controversies might have been addressed and resolved by state courts examining state law, making the federalcourts' involvement unnecessary. Justice Frankfurter also said that the state courts were better equipped to examine ambiguities in the state law:
Frankfurter thus spelled out when the abstention doctrine applied. A federalcourt should not hear a case when a state statute, ambiguous and not yet definitively interpreted by a state court, is challenged at the federal level onconstitutional grounds. By abstaining, the federal courts gave the state courts a chance to resolve the ambiguity and perhaps the constitutional issue. Frankfurter said abstention had been exercised before, if not so clearly defined, and the doctrine was " . . . appropriate to our federal system whereby thefederal court, `exercising a wise discretion,' restrain their authority because of `scrupulous regard for the rightful independence of the state governments' and for the smooth working of the federal judiciary."
The Abstention Doctrine Since Pullman
Justice Frankfurter remained a strong proponent of the abstention doctrine, believing the federal courts should only decide constitutional issues when there was no other way to resolve them. The doctrine was eventually used in a variety of cases, and in 1959 it was extended to civil rights cases (Harrison v. National Association for the Advancement of Colored People).
The doctrine seemed to lose prominence after Frankfurter's retirement in 1962. Some justices expressed displeasure with the doctrine's effects on the litigants. By abstaining, the federal courts forced the parties to begin the legal process again in the state courts, which often took years and created heftylegal expenses.
By the 1970s, the Court tended to find that using the abstention doctrine wasthe exception, not the rule, even when the grounds for exercising it were present. Judges have leeway to hear a case that might qualify for abstention, if a statute violates basic freedoms.
Related Cases
Railroad Commission of Texas, et al.
Appellee
Pullman Company, et al.
Appellant's Claim
That under Texas law it had authority to regulate Pullman sleepers, and thata federal district court erred in preventing enforcement of this regulation.
Chief Lawyers for Appellant
Cecil A. Morgan, Cecil C. Rotsch
Chief Lawyer for Appellee
Ireland Graves
Justices for the Court
Hugo Lafayette Black, William O. Douglas, Felix Frankfurter (writing for theCourt), Charles Evans Hughes, James Clark McReynolds, Frank Murphy, Stanley Forman Reed, Harlan Fiske Stone
Justices Dissenting
None (Owen Josephus Roberts did not participate)
Place
Washington, D.C.
Date of Decision
3 March 1941
Decision
Reversed the lower court's order to enjoin enforcement of the regulation anddirected the case be heard in the state courts.
Significance
The Pullman decision clearly articulated for the first time the Supreme Court's "abstention doctrine." This doctrine defines when a federal court may choose not to exercise its jurisdiction, even though a constitutional issue exists, to first let a state court try to resolve the question. As used inPullman, the abstention doctrine frees the states from having the federal government unnecessarily involved in their affairs.
The Supreme Court has often limited the cases it hears, based on its interpretation of Article III of the Constitution, which established the Court. At times, acts of Congress, such as the Judiciary Acts of 1789 and 1875, have alsolimited or expanded the Court's jurisdiction. For many years, however, the Court seemed to follow the words of Chief Justice John Marshall: "It is most true, that this Court will not take jurisdiction if it should not: but it is equally true, that it must take jurisdiction if it should . . . We have no more right to decline the exercise of jurisdiction which is given, than to usurpthat which is not given."
But Marshall's view was not absolute. In the 1930s, the Court heard a numberof cases in which it could have ruled, but chose not to, or ordered other federal courts to defer to the state courts. This idea of abstaining from jurisdiction was first clearly stated in Railroad Commission of Texas v. PullmanCompany, and is sometimes called the Pullman abstention doctrine.
After the Civil War, George Pullman invented the luxury railroad sleeping carand helped revolutionize transcontinental travel in America. In the 1940s, the Pullman Company was still a major force in train travel. When the Texas Railroad Commission issued an order that affected staffing on Pullman sleepers,the company, along with the railroad lines, took the matter to court.
Race, Economics, and State Law
On the less populated stretches of Texas, railroads usually equipped their trains with just one Pullman car. When a train had just one Pullman, the car was under the control of a porter, who reported to the train conductor. Trainswith more than one Pullman had their own Pullman conductor. At the time, theporters were all African American; the Pullman conductors were all white. TheTexas Railroad Commission issued an order requiring all trains traveling through Texas to have a Pullman conductor in charge of all sleeping cars.
The order was generally interpreted as racially based, as it would provide jobs for more white conductors in Texas. The order may have also been an attempt to deprive the black porters of any authority on the trains. In any event,the Pullman Company and the railroads filed suit in federal district court, seeking to enjoin the order. The companies argued that the order was not authorized under Texas law and violated their due process and equal protection rights, as defined in the Fourteenth Amendment. The Pullman porters also joinedthe suit, claiming the commission's order violated the Fourteenth Amendment by discriminating against blacks.
The district court found it had jurisdiction on the matter and said Texas lawdid not give the commission authority to issue the order. The court forbadethe order from taking effect. The Texas Railroad Commission then appealed tothe Supreme Court. In a 7-0 ruling, the Court said the district court shouldhave abstained from deciding this case and let the state courts decide the issue. The Court reversed the lower court's ruling and, while acknowledging thedistrict court's jurisdiction, ordered the matter to be heard in the state courts.
In his decision, Justice Frankfurter admitted the case brought up meaningfulconstitutional issues. But the constitutional controversies might have been addressed and resolved by state courts examining state law, making the federalcourts' involvement unnecessary. Justice Frankfurter also said that the state courts were better equipped to examine ambiguities in the state law:
What practices of the railroads may be deemed to be `abuses' subject tothe Commission correction is . . . doubtful. Reading the Texas statutes and the Texas decisions as outsiders without special competence in Texas law, we would have little confidence in our independent judgement regarding the application of that law to the present situation . . . The last word on the statutory authority of the Railroad Commission in this case belongs neither to us nor to the district court but to the Supreme Court of Texas.
Frankfurter thus spelled out when the abstention doctrine applied. A federalcourt should not hear a case when a state statute, ambiguous and not yet definitively interpreted by a state court, is challenged at the federal level onconstitutional grounds. By abstaining, the federal courts gave the state courts a chance to resolve the ambiguity and perhaps the constitutional issue. Frankfurter said abstention had been exercised before, if not so clearly defined, and the doctrine was " . . . appropriate to our federal system whereby thefederal court, `exercising a wise discretion,' restrain their authority because of `scrupulous regard for the rightful independence of the state governments' and for the smooth working of the federal judiciary."
The Abstention Doctrine Since Pullman
Justice Frankfurter remained a strong proponent of the abstention doctrine, believing the federal courts should only decide constitutional issues when there was no other way to resolve them. The doctrine was eventually used in a variety of cases, and in 1959 it was extended to civil rights cases (Harrison v. National Association for the Advancement of Colored People).
The doctrine seemed to lose prominence after Frankfurter's retirement in 1962. Some justices expressed displeasure with the doctrine's effects on the litigants. By abstaining, the federal courts forced the parties to begin the legal process again in the state courts, which often took years and created heftylegal expenses.
By the 1970s, the Court tended to find that using the abstention doctrine wasthe exception, not the rule, even when the grounds for exercising it were present. Judges have leeway to hear a case that might qualify for abstention, if a statute violates basic freedoms.
Related Cases
- Harrison v. National Association for the Advancement of Colored People, 360 U.S. 167 (1959).
- Stuart Circle Parish v. Board of Zoning Appeals of City of Richmond, 946 F.Supp. 1225 (1996).
- Roe v. City of Milwaukee, WL 790728 (E.D.Wis. 1998).
Further Readings
- Biskupic, Joan, and Elder Witt. Guide to the U.S. Supreme Court. Washington, DC: Congressional Quarterly, Inc., 1997.
- Hall, Kermit L., ed. The Oxford Companion to the Supreme Court of theUnited States. New York: Oxford University Press, 1992.
- Nowak, John E., Ronald D. Rotunda, and J. Nelson Young. ConstitutionalLaw, 2nd ed. St. Paul: West Publishing Company, 1984.
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