In the 1981 case Railway Labor Executives' Association v. Gibbons, Trustee, et al., the U.S. Supreme Court ruled that a federal law specifically designed to force striking railway workers back to work was unconstitutional because it violated the Bankruptcy Clause of the Constitution and exceeded Congress's power under Article I Section 8. The law in question had been enacted by Congress during a strike at Rock Island Railroad Company with an aim to resolve its bankruptcy proceedings and end labor disputes between management and employees. However, since this legislation targeted only one company rather than having general applicability, it was deemed as "private" or "local" legislation which is prohibited by the uniformity requirement of Bankruptcy Clause.

In the dissenting opinion for Railway Labor Executives' Association v. Gibbons, Justice Blackmun argued that Congress has broad power under the Bankruptcy Clause and can enact laws with specific applications without violating the uniformity requirement. He disagreed with the majority's interpretation of "uniform Laws on the subject of Bankruptcies," arguing that it should not be read so narrowly as to prohibit legislation addressing a particular bankruptcy case or debtor. The justice pointed out historical instances where Congress passed bankruptcy laws targeting specific situations, suggesting this is within their constitutional authority. Furthermore, he contended that there was no violation of due process because all parties involved had an opportunity to present their cases in court before any action was taken against them by law.