[1] This form of abstention allows state courts to correct things like equal protection violations for themselves, thus avoiding the embarrassment of having state policy corrected by the federal courts.

The Railroad Commission of Texas, an administrative agency in Texas issued an order requiring sleeping cars on trains to be staffed by conductors (who were white) instead of by porters (who were black).

The railroad and the Pullman Company, as well as the Brotherhood of Sleeping Car Porters, sued, alleging a violation of Fourteenth Amendment equal protection.

The case was initially considered by a three-judge panel of one Circuit Court judge and two local District Court judges, who held that the agency action violated the law of Texas.

Through a number of later decisions, courts clarified that in order for Pullman abstention to be invoked, three conditions must be apparent: The mechanics of employing the doctrine were refined in Government and Civil Employees Organizing Committee, CIO v. Windsor,[2] and England v. Louisiana State Board of Medical Examiners.