Abstention Doctrine

• Author: Jeffrey Lehman, Shirelle Phelps

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The concept under which a federal court exercises its discretion and equitable powers and declines to decide a legal action over which it has jurisdiction pursuant to the Constitution and statutes where the state judiciary is capable of rendering a definitive ruling in the matter.

The abstention doctrine was adopted by the Supreme Court to allow the federal judiciary to refrain from ruling on constitutional questions. Because it has no explicit source in federal or state laws, it is the exception to the general rule that a litigant may sue or be sued in federal court if the federal court has jurisdiction, or power to hear the case. A federal court has jurisdiction over several species of cases and controversies, such as those involving a federal constitutional question, a federal statute, or litigants of different states in a dispute totaling over $50,000 (in which case, the court's power to hear is called diversity jurisdiction). Federal courts have an obligation to hear the cases properly brought before them, so abstention is an extraordinary judicial maneuver.

Also known as the Pullman doctrine, the abstention doctrine was first fashioned by the Court in Railroad Commission of Texas v. Pullman Co., 312 U.S. 496 61 S. Ct. 643, 85 L. Ed. 971 (1941). At issue in Pullman was a Texas Railroad Commission regulation that prevented the operation of sleeping cars on trains without a Pullman conductor. Before the regulation, Texas trains used only one sleeping car in areas of light passenger traffic. When only one sleeping car was used, the trains had only Pullman porters to watch over the sleepers. When more sleeping cars were used, the trains employed Pullman conductors, who supervised the porters. The regulation eliminated a practice that deprived conductors of wages, but it also effectively decreased the earnings and eliminated the autonomy of porters. This result introduced the

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issue of discrimination, since, at the time, Pullman conductors were white and porters were black.

The Pullman Company and Texas railroads objected to the regulation, and together they brought suit in federal district court to keep the commission from enforcing the order. Pullman porters joined the Pullman Company and the railroads as complainants, and Pullman conductors joined the commission as defendants. The federal district court granted the request of the complainants, ruling that the commission did not have the authority to make such an...