Venue: | SCOTUS |
Facts: | TX enacts a law that basically says that on a sleeper car, you need to have at least one conductor (i.e., a white person), and not just porters (who were black). Pullman wants to do otherwise, because white employees are more expensive. Good grief, nobody looks very good here. |
Posture: | Pullman sues in federal court to enjoin the TX railroad commission's order. Porters intervened as complainants, and conductors intervened in support of the order. The court issued the injunction. Appeal. |
Issue: | Is the order violative of TX law, and the Equal Protection, Due Process, and Commerce clauses of the constitution? |
Holding: | That's for you to find out-- remanded to determine whether this could be adequately settled in state court. |
Rule: | In sensitive issues of social policy, the federal courts ought not to get involved unless there's no alternative to ajudication, and a definitive state ruling would be a an example of a good alternative. |
Reasoning: | We don't want to make unnecessary constitutional determinations.
Here, it's not clear whether this order actually counts as "discrimination" under TX law. In addition, it's not clear whether the commission can really "correct" such "abuses" by the railroads. Really, the TX supreme court should be the final declarer of TX law, and that includes having the last word on the authority of the railroad commission. We need to exercise "wise discretion" and restrain our authority because of "scrupulous regard for the rightful independence of state governments." We'd hardly be furthering the development of the law by issuing a ruling that would later be supplanted by a controlling decision by a state court. We want to avoid the waste of a tentative decision as well as the friction of premature constitutional ajudication. |
Dicta: | The history of equity jurisdiction is the history of regard for public consequences in issuing the extraordinary remedy of injunction. Even if congress hasn't prevented us from exercising our equitable powers, we're able to restrain ourselves, in the furtherance of harmony. |