## Facts

- The Railroad Commission of Texas ordered that no sleeping car could operate in Texas unless it was continuously in the charge of an employee with the rank and position of Pullman conductor.
- On certain Texas routes with light passenger traffic, trains ran with a single Pullman sleeping car supervised by a porter under the train conductor’s general authority, without a separate Pullman conductor.
- Pullman Company and several railroads sued in federal court, alleging the order was unauthorized by Texas statutes and violated the Equal Protection, Due Process, and Commerce Clauses.
- Pullman porters intervened, primarily asserting that the order discriminated against Black porters in violation of the Fourteenth Amendment.
- A three-judge federal district court enjoined enforcement of the Commission’s order, holding the Commission lacked authority under Texas law.

## Issues

1. Whether a federal court should decide federal constitutional challenges to a state agency order when the dispute also turns on an uncertain, potentially dispositive question of state law.
2. Whether the federal court should withhold decision and require the parties to obtain a definitive state-court construction of the relevant Texas statutes before reaching the federal constitutional questions.

## Decision

- The Supreme Court reversed the federal injunction.
- The Court held the federal court should abstain from deciding the federal constitutional issues until Texas courts authoritatively construed the unsettled state-law questions regarding the Commission’s statutory authority.
- The Court directed that the controversy be remitted to state-court proceedings to secure a definitive ruling on state law that could terminate the case or materially alter the constitutional analysis.
- The federal court was to withhold constitutional adjudication while state-court clarification was pursued, rather than treating the federal constitutional questions as immediately ripe for decision.

## Legal Principles

- When a federal constitutional claim depends on an uncertain issue of state law whose resolution may avoid or materially change the constitutional question, a federal court may defer to state courts for an authoritative construction of state law (Pullman abstention).
- Federal courts should avoid premature constitutional rulings, particularly when state-law clarification provides an available path to resolve the dispute without reaching constitutional questions.
- In suits seeking injunctive relief against state action, federal courts may exercise equitable discretion to reduce friction with state governance that could result from tentative federal constructions of unclear state statutes.
- Abstention postpones, but does not forfeit, federal adjudication of federal rights; the federal court may retain jurisdiction to address any remaining constitutional issues after state-court resolution of state law.

## Conclusion

The Court required federal courts to withhold decision on constitutional challenges to a state regulatory order where unsettled state-law issues might be dispositive, directing the parties to obtain an authoritative state-court construction first and establishing the doctrine now known as Pullman abstention.


R.R. Comm'n of Tex. v. Pullman Co., 312 U.S. 496 (1941)