England v. Louisiana State Board of Medical Examiners 375 U.S. 411 (1964) was a United States Supreme Court decision that refined the procedures for U.S. federal courts to abstain from deciding issues of state law, pursuant to the doctrine set forth in Railroad Commission v. Pullman Co., 312 U.S. 496 (1941). Court citation is a standard system used in common law countries such as the United States, United Kingdom, and Canada to uniquely identify the location of past court cases in special series of books called reporters. ... 1964 was a leap year starting on Wednesday (link will take you to calendar). ... The Supreme Court Building, Washington, D.C. The Supreme Court Building, Washington, D.C., (large image) The Supreme Court of the United States, located in Washington, D.C., is the highest court (see supreme court) in the United States; that is, it has ultimate judicial authority within the United States... The United States federal courts are the system of courts organized under the Constitution and laws of the federal government of the United States. ... An abstention doctrine is any one of several doctrines that a United States federal court might (or in some cases must) apply to refuse to hear a case, when hearing the case would potentially intrude upon the powers of the state courts. ... A U.S. state is any one of the 50 states which have membership of the federation known as the United States of America (USA or U.S.). The separate state governments and the U.S. federal government share sovereignty. ... Law (a loanword from Danish- Norwegian lov), in politics and jurisprudence, is a set of rules or norms of conduct which mandate, proscribe or permit specified relationships among people and organizations, provide methods for ensuring the impartial treatment of such people, and provide punishments for those who do not follow... Railroad Commission v. ... Court citation is a standard system used in common law countries such as the United States, United Kingdom, and Canada to uniquely identify the location of past court cases in special series of books called reporters. ... 1941 was a common year starting on Wednesday (link will take you to calendar). ...

Facts

The plaintiffs were chiropractors in the state of Louisiana. They sued in the United States District Court to prevent state officials from applying a licensing scheme to them, arguing both that they were not within the group to whom the statute applied, and that the statute was unconstitutional. The District Court noted that a state court might find that the state law did not apply to the plaintiffs, and abstained from hearing the case pursuant to the Pullman abstention doctrine. The plaintiff, claimant, or complainant is the party initiating a lawsuit, (also known as an action). ... Chiropractic treatment uses manipulative therapy to correct subluxation, which has been shown to have some efficacy in treating back and neck pain, headache, and other symptoms of spinal-related conditions. ... State nickname: Pelican State Other U.S. States Capital Baton Rouge Largest city New Orleans Governor Kathleen Blanco Official languages None; English and French de facto Area 134,382 km² (31st)  - Land 112,927 km²  - Water 21,455 km² (16%) Population (2000)  - Population 4,468,976 (22nd)  - Density 39. ... The United States district courts are the general trial courts of the United States federal court system. ...

The plaintiffs noted that a case refining Pullman called Government and Civil Employees Organizing Committee, CIO v. Windsor, 353 U.S. 364 (1957) had held that the judgment of the state court was meaningless unless the state court was aware that constitutional questions had also been raised as to the validity of the statute. The plaintiffs therefore brought both claims in the Louisiana state court (as they believed Pullman and Windsor required). The state court found against them on both statutory and constitutional claims. Court citation is a standard system used in common law countries such as the United States, United Kingdom, and Canada to uniquely identify the location of past court cases in special series of books called reporters. ... 1957 was a common year starting on Tuesday (link will take you to calendar). ...

The plaintiffs then returned to the District Court seeking a new hearing on the constitutional question. The defendant then sought a dismissal on res judicata grounds, contending that the decision of the state court was binding as to the constitutional issue. In Common law, a defendant is any person who is required to answer the complaint of a plaintiff in a civil suit or any person who has been named in a criminal information or criminal complaint and stands accused of violating a criminal statute. ... Res judicata (Latin for a thing decided) is a common law doctrine meant to bar relitigation of cases between the same parties in court. ...

Issue

Can the federal court hear the case once the state has ruled on the merits of the constitutional issue?

Result

The Supreme Court, in an opinion by Justice Brennan, noted that the state court determination would indeed bind the federal court. The proper procedure, the Court determined, is to give notice that the federal issue is contended, but to expressly reserve the claim on the federal issue for the federal court. If such a reservation is made, the parties can return to the federal court, even if the state court makes a ruling on the issue. William Joseph Brennan (April 25, 1906 - July 24, 1997) was an Associate Justice of the Supreme Court of the United States. ...

However, the Court also noted that even if the parties did not expressly reserve the federal issues, they can still return to the federal court if it is apparent that the parties had avoided adjudication of the state law issues.

Because the plaintiffs in this case believed that they were just following the law as required, they would not be barred from continuing in the federal court.