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Railroad Commission of Texas v. Pullman Company


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 in Pullman, 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 also limited 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 usurp that which is not given."

But Marshall's view was not absolute. In the 1930s, the Court heard a number of 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. Pullman Company, and is sometimes called the Pullman abstention doctrine.

After the Civil War, George Pullman invented the luxury railroad sleeping car and 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.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1941 to 1953Railroad Commission of Texas v. Pullman Company - Significance, Race, Economics, And State Law, The Abstention Doctrine Since Pullman