## Facts

- Chiropractors sought to practice in Louisiana without meeting medical-education requirements imposed by the Louisiana Medical Practice Act.
- They sued in federal district court for injunctive and declaratory relief, asserting (1) the Act did not apply to chiropractors as a matter of state law and (2) if it did, it violated the Fourteenth Amendment.
- A three-judge federal district court abstained under Pullman, directing the parties to pursue state-court resolution of the state-law coverage issue.
- In state court, the chiropractors presented both their state-law argument and their federal constitutional claims; the Louisiana courts rejected both.
- The chiropractors returned to federal court seeking decision of their Fourteenth Amendment claims.
- The federal district court dismissed, reasoning that the state courts had already decided the federal issues and that any further review lay only by direct Supreme Court review of the state judgment.

## Issues

1. After a federal court abstains under Pullman to obtain an authoritative state-law ruling, may the plaintiff return to federal district court for adjudication of federal constitutional claims?
2. If the plaintiff litigates federal constitutional claims in state court during the abstention period, when does that conduct constitute an election that bars later federal-court determination of those claims?

## Decision

- The Supreme Court reversed and remanded for the federal district court to decide the Fourteenth Amendment claims.
- A plaintiff remitted to state court by Pullman abstention retains the right to return to federal court for determination of federal claims after the state courts authoritatively resolve the state-law question.
- If a plaintiff freely and without reservation submits federal claims to the state courts for decision, litigates them, and obtains a decision, the plaintiff is treated as having elected the state forum for those federal issues and cannot relitigate them in federal district court.
- Prior precedent requiring state courts to be informed of federal questions does not require plaintiffs to seek final state-court adjudication of those federal claims.
- On this record, the chiropractors were not deemed to have made a binding election to forgo a federal forum, so dismissal was improper.

## Legal Principles

- Pullman abstention postpones federal adjudication to allow state courts to clarify uncertain state law; it does not automatically forfeit access to a federal forum for federal constitutional claims.
- A plaintiff may satisfy the requirement that state courts be alerted to federal issues while reserving federal claims for final federal adjudication.
- A clear, on-the-record reservation in state court that federal claims are presented only to permit state-law construction, coupled with an intent to return to federal court, prevents an election finding (the “England reservation”).
- Absent a clear and voluntary election to have state courts finally decide federal issues, federal courts should not treat abstention-driven state litigation as a waiver of the federal forum.
- When federal claims are actually submitted for final decision and decided in state court without reservation, ordinary preclusion principles bar a second federal determination of those claims.

## Conclusion

The Court held that Pullman abstention preserves a plaintiff’s ability to return to federal court for federal constitutional adjudication after state-law clarification, unless the plaintiff clearly elects the state courts as the forum for final decision of the federal issues; plaintiffs can avoid election by expressly reserving their federal claims on the state-court record.


England v. La. State Bd. of Med. Exam'rs, 375 U.S. 411 (1964)