In the context of abstention, the reign of law is hardly promoted if an unnecessary ruling of a federal court is supplanted by a controlling decision of a state court. The resources of equity are equal to an adjustment that will avoid the waste of a tentative decision as well as the friction of a premature constitutional adjudication.
The state railroad commission ordered that no sleeping car could be operated on any line of railroad in the state unless such cars were continuously in the charge of an employee having the rank and position of "Pullman" conductor. Thereupon, appellee "Pullman" company and the railroads affected brought suit to enjoin the order on the ground that it violated the Equal Protection, Due Process, and Commerce Clause, as well as U.S. Const. amend XIV. The lower court enjoined enforcement of the order, and an appeal was taken to the Supreme Court of the United States.
Should the Supreme Court of the United States abstain from hearing the case?
The matter of staffing sleeping cars with the "Pullman" company's employees was remanded, with directions to retain the bill pending a determination of proceedings, to be brought with reasonable promptness, in the state court as invocation of the doctrine of abstention in regards to appellant state railroad commission's order was proper. The Court found that the doctrine of abstention was appropriate as the law of Texas appeared to furnish easy and ample means for determining appellant's authority, and if there were difficulties in the procedure, the issue of state law could be settled by appropriate action on the part of the state to enforce obedience to the order. The Court found that in the absence of any showing that the obvious methods for securing a definitive ruling in the state courts could not be pursued with full protection of the constitutional claim, the district court should have exercised its wise discretion by staying its hands.