The U.S. Supreme Court case Bray v. Alexandria Women's Health Clinic in 1992 revolved around the interpretation of a federal law originally designed to protect African Americans from the Ku Klux Klan, and whether it could be used against anti-abortion protestors who block access to clinics. The court ruled in favor of Jayne Bray and other anti-abortion activists by a 6-3 vote, stating that obstructing access to abortion clinics did not amount to discrimination against women as a class because opposition was not based on gender but rather on objection towards abortion itself. This ruling limited the ability for federal courts to intervene in such protests under this particular statute.

In the dissenting opinion for Bray v. Alexandria Women's Health Clinic, Justice Blackmun argued that the majority misinterpreted both the intent and language of federal civil rights law. He contended that anti-abortion protests were indeed a form of gender discrimination because they specifically targeted services used by women. Furthermore, he asserted that these protests were not merely expressions of free speech but rather constituted a conspiracy to deny women their constitutional rights through intimidation and physical obstruction. The majority’s narrow interpretation, according to Blackmun, failed to acknowledge this reality and thus undermined Congress' intent in passing civil rights legislation - which was designed precisely to protect marginalized groups from such conspiratorial actions aimed at denying them equal protection under law.