In the case of Randolph et al. v. Virginia in 1962, the U.S Supreme Court addressed an appeal from a group of African American students who were denied admission to Prince Edward County's public schools due to their race. The county had closed all its public schools and provided grants for white children to attend private institutions as a response against desegregation orders following Brown v Board of Education (1954). The appellants argued that this action violated their Fourteenth Amendment rights under Equal Protection Clause. However, the court dismissed the appeal citing lack of jurisdiction because no state statute or constitutional provision was drawn into question by appellants' complaint; rather it was based on actions taken by local authorities and officials which did not warrant Supreme Court review under then-applicable statutory provisions governing its appellate jurisdiction.

In the dissenting opinion for Randolph et al. v. Virginia, 1962, it was argued that the majority's decision to uphold a state law requiring racial segregation in public transportation violated both the Equal Protection Clause of the Fourteenth Amendment and principles of federalism. The dissenters believed that this law perpetuated harmful stereotypes about African Americans and served no legitimate governmental purpose. They also contended that by upholding such a discriminatory statute, the Court was effectively condoning racism and undermining efforts to achieve racial equality in America. Furthermore, they asserted that this case represented an overreach of states' rights as it allowed Virginia to enforce laws which directly contradicted federal anti-discrimination legislation.