Federal Practice Manual for Legal Aid Attorneys: 2.8.7 The Pullman Doctrine
The Supreme Court announced this aspect of abstention, known as Pullman abstention, in Railroad Commission v. Pullman Co. In Pullman, the railroad sued a state regulatory agency. The railroad challenged on Fourteenth Amendment grounds the requirement that all trains in Texas have a conductor in each sleeping car. Employment in the railroad industry was racially segregated; whites were employed as conductors, while African Americans performing similar work were employed as porters. Thus, the regulation had a discriminatory impact on African Americans.