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Meanwhile, the Supreme Court, like Congress, showed misgivings concerning this aspect of government by injunction.

Drawing upon the traditional discretion of the chancellor, Mr. Justice Holmes introduced a series of self-imposed judicial restraints that culminated in Mr. Justice Frankfurter's famous doctrine of abstention.

Whereas the earlier cases turned rather narrowly upon the availability of adequate state remedies, the new emphasis is upon the nature of the state policy at issue.

The classic case is Railroad Commission v. Pullman.

The commission had issued an administrative order which was challenged as discriminatory against Negroes.

Its enforcement was enjoined by a federal trial court.

On review the Supreme Court, via Mr. Justice Frankfurter, found southern racial problems `` a sensitive area of social policy on which the federal courts ought not to enter unless no alternative to adjudication is open ''.

An alternative was found in the vagueness of state law as to whether the offending order had in fact been authorized.

Reluctant, as usual, to interpret state legislation -- such interpretation can only be a `` forecast rather than a determination '' -- Mr. Justice Frankfurter led a unanimous Court to vacate the injunction.

But it is crucial that here, unlike Burford, the trial court was ordered to retain the case until the state courts had had a reasonable opportunity to settle the state-law question.

`` The resources of equity are equal to an adjustment that will avoid the waste of a tentative decision as well as the friction of a premature constitutional adjudication ''.