Railroad Commission of Texas v. Pullman Company

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. Trains with more than one Pullman had their own Pullman conductor. At the time, the porters were all African American; the Pullman conductors were all white. The Texas 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 joined the 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 law did not give the commission authority to issue the order. The court forbade the order from taking effect. The Texas Railroad Commission then appealed to the Supreme Court. In a 7-0 ruling, the Court said the district court should have abstained from deciding this case and let the state courts decide the issue. The Court reversed the lower court's ruling and, while acknowledging the district court's jurisdiction, ordered the matter to be heard in the state courts.

In his decision, Justice Frankfurter admitted the case brought up meaningful constitutional issues. But the constitutional controversies might have been addressed and resolved by state courts examining state law, making the federal courts' 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 to the 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 federal court 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 on constitutional 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 the federal 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."