In the 1947 case Patton v. Mississippi, the U.S. Supreme Court unanimously overturned an African American man's conviction by an all-white jury for murder in Mississippi state court on grounds of racial discrimination during jury selection process. The defendant, Willie Vinson (alias Patton), argued that black citizens had been systematically excluded from both grand and petit juries in Jefferson Davis County for over a quarter century, violating his Fourteenth Amendment rights to equal protection under law. The State contended that there was no evidence of intentional exclusion based on race but rather due to lack of qualifications or availability among potential black jurors. However, the Supreme Court rejected this argument stating it was not enough for states to deny discriminatory intent; they must also demonstrate absence of discriminatory impact in their actions which Mississippi failed to do so convincingly.

In the dissenting opinion for Patton v. Mississippi, Justice Frankfurter argued that the Court had overstepped its bounds by reevaluating evidence and making determinations about state law, a role he believed should be left to state courts. He contended that it was not within the Supreme Court's jurisdiction to decide whether or not there was racial discrimination in jury selection unless it was so obvious as to constitute a denial of due process under federal law. In this case, he did not believe such clear discrimination existed and therefore disagreed with the majority's decision to overturn Patton's conviction on these grounds.