In Brown v. General Services Administration (1975), the U.S. Supreme Court ruled that Title VII of the Civil Rights Act of 1964, as amended by the Equal Employment Opportunity Act of 1972, provided exclusive judicial remedy for claims of discrimination in federal employment. The case was brought forward by an African American employee who alleged racial discrimination and sought relief through various legal avenues including a class action suit under Title VII and individual actions based on Fifth Amendment due process violations. The court held that Congress intended to create an exclusive, pre-emptive administrative and judicial scheme for resolving complaints about discriminatory treatment in federal employment with passage of these acts. Therefore, it concluded that other forms of legal recourse were not available to those alleging such discrimination.

In the dissenting opinion for Brown v. General Services Administration, Justice William Rehnquist argued that the majority's decision to uphold Section 717 of the Civil Rights Act of 1964 was a misinterpretation of Congressional intent. He contended that Congress did not intend for this section to provide an exclusive remedy for federal employees alleging racial discrimination in employment practices. Instead, he believed it was meant as an additional avenue through which victims could seek redress. By interpreting it as such, Justice Rehnquist felt that the Court had unnecessarily restricted federal employees' rights and limited their access to justice by forcing them into a single procedural pathway rather than allowing them multiple options under existing laws and regulations.