England v. Louisiana State Board of Medical Examiners

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).

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 infringed the Fourteenth Amendment to the United States Constitution. 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 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.

The plaintiffs then returned to the District Court seeking a new hearing on the constitutional question. The defendant...
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