Result
The Supreme Court, in an opinion by Justice Brennan, noted that the state court determination would indeed bind the federal court. The proper procedure, the Court determined, is to give notice that the federal issue is contended, but to expressly reserve the claim on the federal issue for the federal court. If such a reservation is made, the parties can return to the federal court, even if the state court makes a ruling on the issue.
However, the Court also noted that even if the parties did not expressly reserve the federal issues, they can still return to the federal court if it is apparent that the parties had avoided adjudication of the state law issues.
Because the plaintiffs in this case believed that they were just following the law as required, they would not be barred from continuing in the federal court.
Read more about this topic: England V. Louisiana State Board Of Medical Examiners
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