In the Nash v. Florida Industrial Commission case of 1967, the U.S. Supreme Court ruled in favor of a black woman named Virgie Mae Nash who was denied unemployment benefits after she quit her job due to racial discrimination and harassment. The court held that state denial of unemployment compensation benefits to an individual who leaves employment for good cause is not inconsistent with federal law or policy against racial discrimination in employment under Title VII of the Civil Rights Act of 1964. However, it also stated that if a person quits their job because they were being racially discriminated against, then denying them unemployment benefits would be contrary to federal policy on combating racial discrimination at workplaces.

In the dissenting opinion for Nash v. Florida Industrial Commission, Justice Harlan argued that the majority's decision expanded federal jurisdiction too broadly and intruded upon state sovereignty. He contended that while Congress has the power to regulate interstate commerce, it does not have unlimited authority over all aspects of employment relationships within a state. The case involved an employee who was fired after filing a complaint about wage violations with federal authorities; she then sought unemployment benefits from her home state of Florida but was denied because she had been discharged for misconduct (i.e., reporting her employer). The majority ruled in favor of Nash, asserting that states could not punish employees for exercising their federally protected rights without violating those rights themselves. However, Justice Harlan disagreed with this interpretation and believed it went beyond what Congress intended when passing labor laws like Fair Labor Standards Act (FLSA). He maintained that these laws were meant to protect workers' wages and hours rather than shield them from any potential consequences related to their employment status at a local level.