James Phalen was the plaintiff in error in a case against the Commonwealth of Virginia. The dispute arose when Phalen, an African American man, attempted to vote at a polling place but was denied by election officers on account of his race. He then brought suit against the Commonwealth for denying him his right to vote and argued that he had been wrongfully deprived of this right under both state and federal law. The Supreme Court ultimately ruled in favor of Virginia, holding that states have broad authority over their own elections and can deny voting rights based on race if they choose to do so. This ruling effectively overturned any prior decisions which had held otherwise and established racial discrimination as permissible within certain contexts under U.S law until it was later overruled by subsequent cases such as Brown v Board of Education (1954).

In the case of James Phalen v. The Commonwealth of Virginia, the Supreme Court was asked to decide whether a state law that prohibited free African Americans from entering and residing in Virginia violated the Constitution. Justice McLean wrote a dissenting opinion arguing that Congress had no power to pass such laws under Article IV, Section 2 of the Constitution which states "the citizens of each State shall be entitled to all privileges and immunities." He argued that this clause protected individuals from being discriminated against based on their race or place of origin when they traveled between states. Furthermore, he argued that if Congress did have such powers then it would violate other parts of the Constitution including those protecting freedom and liberty for all people regardless of race or color. Ultimately, Justice McLean concluded that while he believed slavery should not exist in any form within United States borders, it was up to individual states rather than Congress to address this issue through legislation as long as it did not conflict with any federal laws already in place.