In Bowen v. United States Postal Service et al., 1982, the Supreme Court ruled that federal agencies are not immune from lawsuits under Section 501 of the Rehabilitation Act of 1973. The case was brought by a postal worker who alleged discrimination based on his physical disability after being denied a promotion due to color blindness. The court held that Congress intended for federal employees to have the same protections against discrimination as those provided in Title VII of the Civil Rights Act and thus could be sued for violations. However, it also clarified that individuals cannot sue for damages but can seek injunctive relief (a court order requiring an entity to stop doing something) or reinstatement if they were unjustly fired or demoted because of their disability.

In the dissenting opinion for Bowen v. United States Postal Service, Justice Thurgood Marshall argued that the majority's interpretation of Section 717 of the Civil Rights Act was too narrow and inconsistent with Congress' intent to provide a broad remedy for employment discrimination in federal government. He contended that by limiting relief under this section only to those who can prove intentional discrimination, many victims would be left without any recourse. Furthermore, he criticized the majority's reliance on legislative history as selective and misleading because it ignored other evidence suggesting Congress intended to include disparate impact claims within Section 717’s scope. Finally, he expressed concern about how this decision could undermine efforts towards achieving equal employment opportunity in federal workplaces.