England v. Louisiana State Board of Medical Examiners

Supreme Court of the United States · 1964 · Federal Courts

Federal CourtsAbstentionabstentionPullmanEngland reservationfederal forumstate court litigationfederal constitutional claims

Facts

Appellants were graduates of chiropractic schools who sought to practice in Louisiana without satisfying the educational requirements of the Louisiana Medical Practice Act. They sued the Louisiana State Board of Medical Examiners in federal court, claiming the Act as applied to them violated the Fourteenth Amendment. The federal district court abstained because a state court might determine that chiropractors were not covered by the statute, and it retained jurisdiction while staying proceedings. In the state courts, appellants did not limit themselves to the state-law applicability question; they also unreservedly presented, briefed, and argued their federal constitutional claims, and the state proceedings ended with a determination against them on both issues.

Issue

When a federal court abstains to allow state-court resolution of state-law issues, may a litigant who originally invoked federal jurisdiction return to federal district court for adjudication of federal constitutional claims after the state courts have also decided those claims? More specifically, when does a litigant's conduct in state court amount to an election to forgo the right to return to federal court?

Rule

Abstention postpones, but does not abdicate, federal jurisdiction. A litigant remitted to state court under abstention may return to federal district court for determination of federal claims unless it clearly appears that he freely and without reservation submitted those federal claims to the state courts for decision, litigated them there, and had them decided there, in which event he has elected to forgo return to the district court whether or not he seeks direct review in the Supreme Court. Government Employees v. Windsor requires only that the litigant inform the state courts of his federal claims so the state statute may be construed in light of them; it does not require full litigation of those federal claims in state court.

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Nina Ortega sued the Arizona Wellness Licensing Council in federal district court in Phoenix, alleging that an ambiguous Arizona licensing statute violated the Fourteenth Amendment as applied to her clinic. The federal court stayed the case under abstention so Arizona courts could decide whether the statute covered her conduct, while expressly retaining jurisdiction. In the ensuing state action, Nina stated on the record that she was identifying her federal constitutional objections only so the Arizona courts could construe the statute in light of them, and that she intended to return to federal court if the state-law issue was resolved against her.

After the Arizona courts reject Nina’s state-law argument and also discuss her federal objections, may she return to federal district court for adjudication of her federal claims?

Explanation. A litigant sent to state court after abstention may return to federal district court unless it clearly appears that she freely and without reservation submitted her federal claims for state-court decision, litigated them there, and had them decided there. An explicit reservation on the state-court record that the federal claims are being exposed only to comply with Windsor preserves the right to return in all events.