In the case of McDonald et al. v. Santa Fe Trail Transportation Co. et al., 1975, two African American employees and a white employee were all involved in stealing company property from their employer, Santa Fe Trail Transportation Company. The company fired only the black employees while retaining the white one who was equally guilty of theft. The dismissed black workers sued under Title VII of the Civil Rights Act alleging racial discrimination by their former employer and union for disparate disciplinary action based on race. The Supreme Court ruled in favor of McDonald and his co-plaintiff, stating that Title VII protects individuals against discriminatory practices regardless of whether they belong to a majority or minority group - thus extending its protections to whites as well as non-whites. It held that an employer cannot discriminate between employees guilty of similar offenses on grounds such as race or color when deciding upon penalties like dismissal.

In the dissenting opinion for McDonald et al. v. Santa Fe Trail Transportation Co., Justice William Rehnquist argued that Title VII of the Civil Rights Act should not be interpreted to protect white employees from racial discrimination in the same way it protects minority groups. He contended that Congress intended this law specifically to address historical and systemic injustices faced by non-white populations, rather than individual instances of prejudice against whites. Therefore, he believed that applying these protections equally across all races was a misinterpretation of legislative intent and could potentially dilute efforts aimed at rectifying institutionalized racism towards minorities.