In the case of Chandler v. Roudebush, 1975, the U.S. Supreme Court ruled that federal employees have a right to trial de novo in discrimination cases under Title VII of the Civil Rights Act of 1964. The plaintiff, Chandler was an employee at a Veterans' Administration hospital who claimed he had been denied promotions due to racial discrimination and sought judicial review after his complaint was dismissed by agency officials and the Civil Service Commission's Appeals Review Board. The District Court dismissed his suit on grounds that it lacked jurisdiction over such matters while appellate court affirmed this decision stating administrative findings were conclusive unless arbitrary or capricious. However, Supreme Court reversed these decisions asserting that Congress intended for aggrieved federal employees to have access to trials de novo as part of their rights under Title VII - meaning they could present their case anew before a different tribunal or court.

In the dissenting opinion for Chandler v. Roudebush, Justice William H. Rehnquist argued that Congress did not intend to provide federal employees with a trial de novo in district court when it passed Title VII of the Civil Rights Act of 1964. He pointed out that this interpretation was inconsistent with other parts of the statute and would lead to an inefficient duplication of administrative proceedings by courts. Furthermore, he believed that such a broad right to judicial review undermined the role and expertise of administrative agencies in resolving employment disputes within their jurisdiction. In his view, if Congress had intended such a significant departure from traditional principles governing judicial review of agency action, it would have made its intention clear in statutory language or legislative history.