The U.S. Supreme Court case Calhoon v. Harvey in 1964 revolved around the issue of whether a labor union's election process violated federal law by only allowing members who had been employed as marine engineers to run for office, excluding other types of workers from candidacy. The plaintiffs, non-engineer members of the National Marine Engineers' Beneficial Association (NMEBA), argued that this rule infringed upon their rights under Section 101(a)(1) of the Labor-Management Reporting and Disclosure Act (LMRDA). However, the Supreme Court ruled against them unanimously. It held that while LMRDA guarantees equal voting rights for all union members, it does not guarantee an equal right to be a candidate in union elections; therefore NMEBA's restriction did not violate federal law.

In the dissenting opinion for Calhoon v. Harvey, Justice Douglas argued that the majority's decision was a misinterpretation of Section 101(a)(1) of the Labor-Management Reporting and Disclosure Act (LMRDA). He believed that this section should be read to provide equal voting rights for all union members in good standing, not just those who meet additional qualifications set by union leadership. According to him, allowing unions to restrict eligibility for office could lead to abuses of power and corruption within labor organizations. Furthermore, he contended that such restrictions were contrary to Congress' intent when it passed LMRDA - which aimed at promoting democracy within labor unions. Therefore, he disagreed with the majority's ruling upholding these restrictions as lawful under LMRDA.