In the 1985 case Equal Employment Opportunity Commission v. Federal Labor Relations Authority, the U.S. Supreme Court ruled that federal agencies must comply with orders from the Federal Labor Relations Authority (FLRA). The dispute arose when a union representing employees of the Equal Employment Opportunity Commission (EEOC) filed an unfair labor practice charge against EEOC for refusing to bargain over certain matters. FLRA ordered EEOC to cease and desist its refusal, but EEOC refused arguing it was not subject to FLRA's jurisdiction as it had been created by separate legislation giving it independence in managing its affairs including labor relations. However, the court held that Congress intended all federal agencies be subject to uniform rules and regulations regarding collective bargaining under supervision of FLRA unless explicitly exempted by law which was not applicable in this case.

In the dissenting opinion for EQUAL EMPLOYMENT OPPORTUNITY COMMISSION v. FEDERAL LABOR RELATIONS AUTHORITY et al., Justice White disagreed with the majority's interpretation of the Civil Service Reform Act (CSRA). He argued that Congress intended to give federal agencies, like EEOC, broad authority over their own employment practices and procedures. The CSRA was designed to promote collective bargaining between federal employees and management but did not intend to limit an agency’s ability to enforce anti-discrimination laws. According to him, this decision could potentially undermine efforts by agencies such as EEOC in enforcing civil rights protections within their organizations. Furthermore, he contended that FLRA should not have jurisdiction over disputes involving discrimination complaints because it lacks expertise in handling such matters compared with EEOC which is specifically tasked by Congress for this purpose.