In Gibson v. Mississippi, the U.S Supreme Court upheld a decision by the Mississippi Supreme Court that denied an African American man's claim of racial discrimination during jury selection for his trial. The defendant, William Gibson, was convicted of murder in 1894 and appealed on grounds that potential black jurors were excluded solely based on their race. However, both courts ruled there was no evidence to support this claim as it could not be proven that qualified black citizens had been available but were intentionally overlooked when forming the jury pool. This case is significant because it demonstrated how difficult it was at the time for defendants to prove racial bias in court proceedings despite widespread discriminatory practices against African Americans during this period.

In the dissenting opinion for Gibson v. Mississippi, Justice John Marshall Harlan argued that the state court's decision to exclude African American jurors solely based on their race was a clear violation of the Equal Protection Clause in the Fourteenth Amendment. He contended that this exclusionary practice not only denied Gibson, an African American defendant, his constitutional right to a fair trial but also perpetuated racial discrimination and inequality within society. Furthermore, he criticized the majority's interpretation of "equal protection" as it allowed states to continue discriminatory practices under guise of local customs or traditions. For him, such interpretation undermined federal authority and weakened constitutional protections against racial discrimination.