In Kremer v. Chemical Construction Corp., the U.S. Supreme Court ruled that a federal court must give preclusive effect to a state administrative agency's decision, as long as it is consistent with due process and does not violate any statute. The case involved an employee who alleged discrimination under Title VII of the Civil Rights Act of 1964 after being fired by his employer, Chemical Construction Corporation. After losing at both the New York State Division of Human Rights and in federal district court, he appealed to the Supreme Court arguing that his claim should not have been dismissed because he had never received a full hearing on its merits in state court or before an administrative law judge (ALJ). However, the Supreme Court disagreed and upheld lower courts' decisions stating that Congress intended for states to play primary role in preventing employment discrimination when it enacted Title VII.

In the dissenting opinion for Kremer v. Chemical Construction Corp., Justice White, joined by Justices Brennan and Marshall, argued that federal courts should not be barred from reviewing state court decisions on civil rights claims under Title VII of the Civil Rights Act of 1964. They contended that Congress did not intend to preclude de novo review in federal court when it amended Title VII in 1972 to allow individuals to pursue their claims initially before state agencies. The majority's interpretation would effectively deny many plaintiffs a full opportunity to litigate their discrimination claims because some states do not provide procedures equivalent to those available at the federal level. Furthermore, they expressed concern about potential inconsistency between state and federal interpretations of Title VII law which could undermine its uniform enforcement across states.