England v. Louisiana State Board of Medical Examiners

England v. Louisiana State Board of Medical Examiners
Supreme Court of the United States
Argued October 15, 1963 Decided January 13, 1964
Full case name	England, et al. v. Louisiana State Board of Medical Examiners, et al.
Citations	375 U.S. 411 (more) 84 S. Ct. 461; 11 L. Ed. 2d 440; 1964 U.S. LEXIS 2264
Prior history	Appeal from the United States District Court for the Eastern District of Louisiana. England v. Louisiana State Board of Medical Examiners, 194 F. Supp. 521, 1961 U.S. Dist. LEXIS 3270 (E.D. La., 1961)
Holding
The Court 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 membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan, Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Brennan, joined by Warren, Clark, Harlan, Stewart, White, Goldberg
Concurrence	Douglas
Concur/dissent	Black
Laws applied
U.S. Const.

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).

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 then sought a dismissal on res judicata grounds, contending that the decision of the state court was binding as to the constitutional issue.