RAILROAD COMMISSION OF TEXAS ET AL.
v.
ROWAN & NICHOLS OIL CO.
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The Supreme Court revised its decision in a case involving the Railroad Commission of Texas and an oil company's challenge to state oil proration regulations, clarifying that federal courts cannot enjoin state regulatory action under the Due Process Clause when the challenged regulation rests on a state statutory standard of "reasonableness." The Court held that federal courts should not circumvent constitutional limits on their review by enforcing equivalent restrictions under the guise of interpreting state law, while leaving open the possibility of remedies in state courts.
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It is ordered that the following sentence-on page 4 of the opinion handed down June 3, 1940, 310 U. S. 580, be stricken from the opinion:
“Except where the jurisdiction rests, as it does not here, on diversity of citizenship, the only question open to a federal tribunal is whether the state action complained of has transgressed whatever restrictions the vague contours of the Due Process Clause may place upon the exercise of the state’s regulatory power.” It is further ordered that the following paragraph be added at the close of the opinion:
“While the presence of a federal question may also open up state issues, Siler v. Louisville & Nashville R. Co., 213 U. S. 175, the claim here founded on Texas law is derived from a statute requiring proration on a ‘reasonable basis.’ Vernon’s Texas Annotated Civil Statutes (1925), art. 6049c, § 7. The Texas decisions, insofar as they have been brought to our attention, do not make clear whether the local courts may exercise an independent judgment on what is ‘reasonable.’ Compare Brown v. Humble Oil & Refining Co., 126 Tex. 296, 316; 83 S. W. 2d 935; 87 S. W. 2d 1069. But, in any event, as we read the Texas cases, the standard of ‘reasonable, basis’ under the statute opens up the same range of inquiry as the respondent in effect asserted to exist in his claims under the Due Process Clause. These latter claims wé have found untenable. What ought not to be done by the federal courts' when the Due Process Clause is invoked ought not to be attempted by these courts under the guise of enforcing a state statute. Whether the respondent may still have a remedy in the state courts is for the Texas courts to determine, and is not foreclosed by the. denial, on the grounds we have indicated, of the extraordinary relief of an injunction in the federal courts.”
The motion for leave to. present oral argument is denied.
The petition for rehearing is denied.
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Burford v. SUN OIL Co., 319 U.S. 315 (U.S. 1943)…ngress. The only limitations upon the exercise of diversity jurisdiction — apart from that which Congress made in the Johnson Act — are, broadly speaking, those illustrated by Railroad Comm’n v. Rowan & Nichols Oil Co., 310 U. S. 573, as amended in 311 U. S. 614-15; Railroad Comm’n v. Pullman Co., 312 U. S. 496; and Chicago v. Fieldcrest Dairies, 316 U. S. 168. In Rowan & Nichols the claim based upon state law was derived from a statute requiring proration on a “reasonable basis,” and it was not clear from…1 / 2
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Ala. Pub. Serv. Comm'n v. S. Ry. Co., 341 U.S. 341 (U.S. 1951)…e pursued through the state courts. Burford v. Sun Oil Co., 319 U. S. 315 (1943); Railroad Commission of Texas v. Rowan & Nichols Oil Co., 311 U. S. 570, 577 (1941); Railroad Commission of Texas v. Rowan & Nichols Oil Co., 310 U. S. 573, as amended, 311 U. S. 614, 615 (1940). The Johnson Act, 48 Stat. 775 (1934), now 28 U. S. C. (Supp. III) § 1342, does not affect the result in this case. That Act deprived federal district courts of jurisdiction to enjoin enforcement of certain state administrative orders a…1 / 2
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First Am. Bank & Tr. Co. v. Ellwein, 474 F.2d 933 (8th Cir. 1973)…Ed. 1424] (1943); Railroad Commission of Texas v. Rowan & Nichols Oil Co., 311 U.S. 570, 577, [61 S.Ct 343, 346, 85 L.Ed. 358] (1941); Railroad Commission of Texas v. Rowan & Nichols Oil Co., 310 U.S. 573, [60 S.Ct. 1021, 84 L.Ed. 1368], as amended, 311 U.S. 614, 615, [61 S.Ct. 66, 85 L.Ed. 390] (1940). [Id. at 349-350, 71 S.Ct. at 768-769 (footnotes omitted).] As already mentioned, the federal district court denied preliminary re [*936] lief on grounds of abstention but the final judgment in form dismisse…
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- Siler et. al. v. Louisville & Nashville R.R. Co., 213 U.S. 175 (U.S. 1909)