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Railroad Commission v. Pullman Co.

Railroad Commission v. Pullman Co.
Seal of the United States Supreme Court.svg
Argued February 4, 1941
Decided March 3, 1941
Full case name Railroad Commission of Texas, et al. v. Pullman Company, et al.
Citations 312 U.S. 496 (more)
61 S. Ct. 643; 85 L. Ed. 971; 1941 U.S. LEXIS 1102
Prior history Appeal from the District Court of the United States for the Western District of Texas
Court membership
Case opinions
Majority Frankfurter, joined by Hughes, McReynolds, Stone, Black, Reed, Douglas, Murphy
Roberts took no part in the consideration or decision of the case.

Railroad Commission v. Pullman Co., 312 U.S. 496 (1941), was a case in which the United States Supreme Court determined that it was appropriate for United States federal courts to abstain from hearing a case in order to allow state courts to decide substantial Constitutional issues that touch upon sensitive areas of state social policy.

This form of abstention allows state courts to correct things like equal protection violations for themselves, thus avoiding the embarrassment of having state policy corrected by the federal courts. Under Pullman abstention, the federal court retains jurisdiction to hear the case if the state court's resolution is still constitutionally suspect.

The Railroad Commission of Texas, an administrative agency in Texas issued an order requiring sleeping cars on trains to be staffed by conductors (who were white) instead of by porters (who were black). The railroad and the Pullman Company, as well as the Brotherhood of Sleeping Car Porters, sued, alleging a violation of Fourteenth Amendment equal protection. The case was initially considered by a three-judge panel of one Circuit Court judge and two local District Court judges, who held the agency action violated the law of Texas. The case was appealed directly to the Supreme Court.

Although the parties did not raise the issue before the United States Supreme Court, this case presented an opportunity for the Court to discuss whether it was appropriate for the United States District Court to grant relief, when the suit could have been brought in a state court in Texas.


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