In Love v. Pullman Co., 1971, the U.S. Supreme Court ruled on a case involving an African American man named Joseph H. Love who was laid off by the Pullman Company and subsequently filed a complaint with the Equal Employment Opportunity Commission (EEOC). The EEOC found reasonable cause to believe that racial discrimination had occurred but failed to achieve voluntary compliance from Pullman through conciliation efforts before filing suit in federal court. The issue at hand was whether or not Mr. Love could file his own lawsuit after these events transpired, despite failing to mention this intention in his initial complaint with the EEOC. The Supreme Court held that it is unnecessary for individuals seeking relief under Title VII of the Civil Rights Act of 1964 to specify their intent to sue within their original charge filed with EEOC; rather they may do so after receiving notice from EEOC about its unsuccessful attempts at reaching an agreement via conciliation process between employer and employee. This ruling effectively broadened access for employees alleging workplace discrimination by allowing them more flexibility when pursuing legal remedies against employers suspected of violating anti-discrimination laws.

In the dissenting opinion for Love v. Pullman Co., Justice William O. Douglas argued that the case should not have been dismissed on procedural grounds, as it was by the majority. He contended that there were significant questions about whether or not racial discrimination had occurred in this case, and these issues deserved to be fully explored in court. Furthermore, he disagreed with the majority's assertion that Mr. Love needed to exhaust all possible remedies within his union before bringing a lawsuit against his employer; such an expectation would place an undue burden on workers seeking justice for discriminatory practices at work, according to Justice Douglas.