Railroad Comm'n of Texas v. Pullman Co., 312 U.S. 496 (1941)
If a state court can easily resolve a certain issue based on state law, a federal court should not intercede to resolve the case.
Some trains in Texas used only one sleeping car during periods of light passenger traffic. Porters, who were mostly African-American, supervised the cars in these situations instead of conductors, who were mostly white. The Railroad Commission of Texas ordered sleeping cars to be operated only when they could be continuously under the oversight of a conductor. The Pullman Co., a manufacturer of sleeping cars, and the railroad companies that used this arrangement sought an injunction in a federal court against the enforcement of this order. They argued that it violated state law and the Constitution. The porters, who intervened in the case, also asserted that the order discriminated on the basis of race in violation of the Fourteenth Amendment. The plaintiffs succeeded in obtaining an injunction, persuading the lower court that Texas laws did not justify the Commission's order.Opinions
- Felix Frankfurter (Author)
- Charles Evans Hughes
- Harlan Fiske Stone
- Owen Josephus Roberts
- Hugo Lafayette Black
- Stanley Forman Reed
- William Orville Douglas
- Frank Murphy
When possible, disputes that raise a sensitive and important social question should be resolved under state law rather than the Constitution. The case may be resolved according to whether the order is consistent with the Commission's power to prevent discrimination. A state court could address this issue, and the decision that it reaches might obviate the need for a federal court to decide the case based on issues that could cause conflicts between the state and federal judicial systems. The federal action should not proceed, therefore, until a state court has reviewed the case on its merits.Case Commentary
Under the abstention doctrine, federal courts generally refrain from addressing a matter that involves a preliminary consideration of issues that arise under state law. As with other cases in this area, the key concerns here include finality and consistent resolutions.
U.S. Supreme CourtRailroad Comm'n of Texas v. Pullman Co., 312 U.S. 496 (1941)
Railroad Commission of Texas v. Pullman Company
Argued February 4, 1941
Decided March 3, 1941
312 U.S. 496
A railroad company, some of whose trains in Texas had each but one Pullman sleeping car and that in charge of a colored porter subject to the control of the train conductor, assailed in the federal court, as unauthorized by Texas statutes and as violative of the Federal Constitution, a regulation by a state commission which would require that such cars be continuously in charge of an employee "having the rank and position of a Pullman conductor." Pullman porters, intervening, also attacked the order, adopting the railroad's objections but urging mainly that it discriminated against Negroes in violation of the Fourteenth Amendment, Pullman porters being Negroes and the conductors white.
1. Decision of the issue of unconstitutional discrimination should be withheld pending proceedings to be taken in the state courts to secure a definitive construction of the state statute. P. 312 U. S. 498.
2. The federal courts, when asked for the extraordinary remedy of injunction, will exercise a sound discretion in the public interest to avoid needless friction with state policies that may result from tentative constructions of state statutes and premature adjudication on their constitutionality. P. 312 U. S. 500.
33 F. Supp. 675, reversed.
APPEAL from a decree of the District Court of three judges which enjoined the enforcement of an order of the above-named Railroad Commission.