U.S. Supreme Court
England v. Medical Examiners, 375 U.S. 411 (1964)
England v. Louisiana State Board of Medical Examiners
Argued October 15, 1963
Decided January 13, 1964
375 U.S. 411
Appellants are chiropractors who seek to practice in Louisiana without complying with the educational requirements of the Louisiana Medical Practice Act. They brought this action against appellee Board of Medical Examiners in a Federal District Court for an injunction and a declaration that, as applied to them, the Act violated the Fourteenth Amendment. A three-judge court invoked the doctrine of abstention and remitted the parties to the state courts on the ground that a decision that the Act does not apply to chiropractors might end the controversy. Appellants then brought proceedings in the state courts, unreservedly submitting for decision not only the state law question, but also their Fourteenth Amendment claims, which were resolved against them. Appellants returned to the District Court, which dismissed the complaint on the ground that the federal questions had been decided by the state courts and the proper remedy was by appeal from the state courts to the Supreme Court.
Held: On the record in this case, the judgment is reversed and the case is remanded to the District Court for decision on the merits of appellants' Fourteenth Amendment claims. Pp. 375 U. S. 412-423.
1. A party remitted to state courts by an abstention order of a Federal District Court has the right to return to the District Court, after obtaining the authoritative state court ruling for which the court abstained, for a determination of his federal claims. Pp. 375 U. S. 415-417.
2. Where a party freely and without reservation submits his federal claims for decision by the state courts, litigates them there, and has them decided there, then -- whether or not he seeks direct review of the state decision in this Court -- he has elected to forgo his right to return to the District Court. Pp. 375 U. S. 417-419.
3. The case of Government Employees v. Windsor, 353 U. S. 364, is not to be read as meaning that a party must litigate his federal claims in the state courts, but only that he must inform chanroblesvirtualawlibrary
those courts what his federal claims are, so that the state statute may be construed "in light of" those claims. P. 375 U. S. 420.
4. A party may readily forestall any conclusion that he has elected not to return to the District Court by making on the state record an explicit reservation to the disposition of the entire case by the state courts; that is, he may inform the state courts that he is exposing his federal claims there only for the purpose of complying with Windsor, and that he intends, should the state courts hold against him on the question of state law, to return to the District Court for disposition of his federal contentions. P. 375 U. S. 421.
5. However, such an explicit reservation is not indispensable, for a litigant is not to be denied his right to return to the District Court unless it clearly appears that he voluntarily did more than Windsor required, and fully litigated his federal claims in the state courts. P. 375 U. S. 421.
6. On the record in this case, the Court does not apply to these appellants the rule here announced, since their primary reason for litigating their federal claims in the state courts was assertedly the view that Windsor required them to do so -- a view which was mistaken, and will not avail other litigants who rely upon it after today's decision, but which was not unreasonable at the time. P. 375 U. S. 422.
194 F. Supp. 521, reversed and remanded.