Alabama Public Service Commission v. Southern Railway Co
In Alabama Pub. Serv. Comm'n v. Southern R. Co., 341 U.S. 341 (1951), a railroad sought to enjoin enforcement of an order of the Alabama Public Service Commission refusing permission to discontinue unprofitable rail lines.
According to the railroad, requiring continued operation of the lines amounted to confiscation of property in violation of federal due process rights.
Under Alabama law, a party dissatisfied with a final order of the Public Service Commission had an absolute right of appeal to the Circuit Court of Montgomery County, which was "empowered to set aside any Commission order found to be contrary to the substantial weight of the evidence or erroneous as a matter of law." Id., at 348.
This right of statutory appeal "concentrated in one circuit court" which exercised "supervisory" powers was, we found, "an integral part of the regulatory process under the Alabama Code." Ibid.
Taking account of the unified nature of the state regulatory process, and emphasizing that "adequate state court review of the administrative order was available," id., at 349, and that the success of the railroad's constitutional challenge depended upon the "predominantly local factor of public need for the service rendered," id., at 347, the Court held that the District Court ought to have abstained from exercising its jurisdiction, id., at 350.
In Alabama Public Service Commission v. Southern Railway Co., 341 U.S. 341, 71 S.Ct. 762, 95 L.Ed. 1002 (1951), a case wherein a railroad sought to enjoin enforcement of an order of the Alabama Public Service Commission denying permission for the discontinuance of unprofitable rail lines, and referring to other cases as well.
In Alabama Public Service Commission, the Court emphasized the importance of the availability of recourse to the state courts:
Not only has Alabama established its Public Service Commission to pass upon a proposed discontinuance of intrastate transportation service, but it has also provided for appeal from any final order of the Commission to the circuit court of Montgomery County as a matter of right. (Ala. Pub. Serv. Comm'n, 341 U.S. at 348, 71 S.Ct. 762.)
The Court stated: "Whatever rights the Railway Company may have are to be pursued through the state courts." Id. at 350, 71 S.Ct. 762.
In Alabama Public Service Comm'n v. Southern Railway Co., 341 U.S. 341, 71 S.Ct. 762, 95 L.Ed. 1002 (1951), a railroad challenged a state commission order that denied it permission to discontinue certain routes. Id. at 342-43, 71 S.Ct. at 764-65.
The relevant legal test was apparently settled, and required "balancing the loss to the railroad from continued operation of the affected routes with the public need for that service." Id. at 347-48, 71 S.Ct. at 767-68.
While the legal framework was clear, the Supreme Court still held abstention proper to avoid "the essentially local problem." Id. at 347, 349-50, 71 S.Ct. at 767, 768-69.
In Alabama Public Service Commission v. Southern Ry. Co., 341 U.S. 341, 71 S.Ct. 762, 95 L.Ed. 1002 (1951), the Supreme Court has upheld a Burford abstention, the power to abstain was again grounded in the discretion afforded equitable courts in granting relief:
This withholding of extraordinary relief by courts having authority to give it is not a denial of the jurisdiction which Congress has conferred on the federal courts.... On the contrary, it is but a recognition ... that a federal court of equity ... should stay its hand in the public interest when it reasonably appears that private interests will not suffer ...
It is in the public interest that federal courts of equity should exercise their discretionary power to grant or withhold relief so as to avoid needless obstruction of the domestic policy of the states. (341 U.S. at 350-51, 71 S.Ct. at 769.)