In the Caldwell v. Texas case of 1890, the U.S. Supreme Court ruled in favor of Henry Caldwell, an African American man who was convicted for participating in a labor strike and sentenced to two years imprisonment by a Texas court. The Supreme Court overturned this conviction on grounds that it violated his Fourteenth Amendment rights which guarantee equal protection under law and due process. The court found that the state statute used to convict him was overly broad and vague, thereby making it unconstitutional as it could be applied arbitrarily or discriminatorily against certain groups such as labor unions or racial minorities like Caldwell himself. This ruling marked one of the early instances where the high court extended federal constitutional protections to individuals against actions by state governments.

In the dissenting opinion for Caldwell v. Texas, Justice Lamar argued that the ordinance in question did not infringe upon any rights protected by the Fourteenth Amendment. He contended that it was within a state's police power to regulate businesses and professions as long as such regulations were reasonable and aimed at protecting public health, safety or welfare. In this case, he believed that regulating funeral processions could be seen as necessary for maintaining order and preventing disturbances on public streets. Furthermore, he suggested that if every local regulation affecting interstate commerce was subject to scrutiny under the Commerce Clause of the Constitution, it would undermine states' ability to govern themselves effectively. Thus, while acknowledging potential issues with how this particular ordinance had been applied in Caldwell's case (which might have warranted relief), Justice Lamar disagreed with his colleagues' broader interpretation of federal constitutional law.