Pullman abstention

An abstention doctrine is any of several doctrines that a court of law in the United States of America may (or in some cases must) 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 (such as federal and state courts within a federal system).

The United States has a federal court system with limitations on the cases that federal courts can hear, while each state has its own individual court system. In some instances, the jurisdiction of these courts overlap, so a lawsuit between two parties may be brought in either or both courts. The latter circumstance can lead to confusion, waste of resources, as well as the appearance that one court is disrespecting the other. Both federal and state courts have developed rules determining when one court will defer to another's jurisdiction over a particular case.

The various abstention doctrines applied by federal courts are named for the United States Supreme Court cases in which they were enunciated.

Pullman abstention was the first "doctrine of abstention" to be announced by the Court, and is named for Railroad Commission v. Pullman Co., 312 U.S. 496 (1941). Concisely, the doctrine holds that "the federal courts should not adjudicate the constitutionality of state enactments fairly open to interpretation until the state courts have been afforded a reasonable opportunity to pass on them." This doctrine permits a federal court to stay a plaintiff's claim that a state law violates the United States Constitution until the state's judiciary has had an opportunity to apply the law to the plaintiff's particular case. The hope is to avoid a federal constitutional ruling by allowing the state courts to construe the law in a way that eliminates the constitutional problem or to rule it void under the state's own constitution.

For Pullman abstention to be invoked, three conditions must be apparent:

Under Pullman abstention, the federal court retains jurisdiction to hear the constitutional issues in the case if the state court's resolution is still constitutionally suspect. In Government and Civil Employees Organizing Committee, CIO v. Windsor, 353 U.S. 364 (1957), the Supreme Court held that litigants must inform the state court that they are contending that the state law violates a federal constitutional provision, so that the state court may take that into consideration when interpreting the state statute. However, in England v. Louisiana State Board of Medical Examiners, 375 U.S. 411 (1964), the Supreme Court noted that the litigants must not ask the state court to resolve the constitutional issue itself, or the federal court would be bound by res judicata to follow the decision of the state court. In such a case, the litigant seeking a judgment that the law is unconstitutional must usually appeal to the higher courts of the state, rather than seeking review in a federal court.

...
Wikipedia