In the 1946 case Morgan v. Virginia, the U.S. Supreme Court ruled that segregation on interstate buses was unconstitutional, violating the Commerce Clause of the Constitution. The case was brought by Irene Morgan, an African American woman who refused to give up her seat and move to the back of a Greyhound bus traveling from Virginia to Maryland in 1944 - a decade before Rosa Parks' similar act of defiance. She was arrested for refusing to comply with state law mandating segregated seating on public transportation within its borders. In a landmark decision, Justice Stanley Reed delivered majority opinion stating that such laws placed undue burden on interstate commerce and were thus invalid under federal law.

In the dissenting opinion for Morgan v. Virginia, Justice Stanley Reed argued that while he agreed with the majority's goal of eliminating racial discrimination, he disagreed with their method of using judicial power to enforce social reform. He believed that such changes should come from legislative action rather than court rulings. Reed contended that it was not within the Court’s jurisdiction to regulate interstate commerce or dictate how private businesses should operate unless there were clear constitutional violations involved. He also expressed concern about potential overreach by federal courts into state affairs and cautioned against undermining states' rights in favor of national uniformity on issues like segregation policies.