In the 1949 case Henderson v. United States et al., Elmer W. Henderson, an African American railway passenger, challenged racial segregation in dining cars on interstate trains. He was denied service in a dining car because of his race and subsequently filed suit against Southern Railway Company for damages under federal law prohibiting racial discrimination in interstate travel accommodations. The Supreme Court ruled unanimously that such practices were illegal under the Interstate Commerce Act (1887). This decision marked one of several instances where the court used its authority to challenge Jim Crow laws and other forms of institutionalized racism prevalent during this era.

In the dissenting opinion for Henderson v. United States et al., Justice Reed argued that the majority's decision to overturn segregation in dining cars on interstate trains was not supported by sufficient evidence or legal precedent. He contended that there was no clear proof of unreasonable, undue, or unjust discrimination against African American passengers as required under the Interstate Commerce Act. Furthermore, he pointed out that previous court decisions had upheld similar practices of racial separation provided they were "separate but equal." Justice Reed also expressed concern about judicial overreach and warned against courts making policy decisions better left to legislative bodies. In his view, it was not within the purview of judiciary to decide whether a particular social practice such as segregation should continue or be abolished; rather its role is merely to interpret and apply existing laws.