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There are fundamental objections to any conclusion that a litigant who has properly invoked the jurisdiction of a federal district court to consider federal constitutional claims can be compelled, without his consent and through no fault of his own, to accept instead a state court's determination of those claims. Such a result would be at war with the unqualified terms in which Congress, pursuant to constitutional authorization, has conferred specific categories of jurisdiction upon the federal courts, and with the principle that when a federal court is properly appealed to in a case over which it has by law jurisdiction, it is its duty to take such jurisdiction. The right of a party plaintiff to choose a federal court where there is a choice cannot be properly denied. Nor does anything in the abstention doctrine require or support such a result.
Forty graduates of chiropractic schools seeking to practice in Louisiana without complying with the educational requirements of the Louisiana Medical Practice Act brought suit in the United States District Court for the Eastern District of Louisiana, seeking an injunction and a declaration that, as applied to them, the statute violated the Fourteenth Amendment. A three-judge Federal District Court, invoking the doctrine of abstention, stayed proceedings until the Louisiana state courts had an opportunity to determine the issue whether the act applied to chiropractors, but retained jurisdiction to take such steps as might be necessary for the just disposition of the litigation should anything prevent a prompt state determination. The chiropractors then brought suit in the Louisiana state courts, where they unreservedly submitted for decision their contention that the statute, if applicable to them, violated the Fourteenth Amendment. The Supreme Court of Louisiana decided that the statute applied to chiropractors and that as so applied it did not violate the Fourteenth Amendment. The chiropractors then returned to the Federal District Court, which dismissed the complaint on the ground that the Louisiana state courts had passed on all the issues raised.
May a litigant in federal court who is remitted to a state court under the doctrine of abstention preserve his right to return to federal court for the disposition of his federal contentions by refusing to litigate his federal contentions in the state court?
The Court held that a litigant in federal court who is remitted to a state court under the doctrine of abstention may preserve his right to return to federal court for the disposition of his federal contentions by refusing to litigate his federal contentions in the state courts. If a party freely and without reservation submits his federal claims for decision by the state courts, litigates them there, and has them decided there, then -- whether or not he seeks direct review of the state decision in the Court -- he has elected to forgo his right to return to the district court. Although the Court's holding supported the district court's order, the Court reversed because appellants' reliance on pre-existing legal authority had been reasonable.