In the case of Rice v. Sioux City Memorial Park Cemetery, Inc., et al., 1954, the U.S. Supreme Court ruled that a private corporation operating a cemetery could not enforce racially discriminatory restrictions on burial plots. The plaintiff, an African American woman named Lucille Rice, had purchased four burial plots at the Sioux City Memorial Park Cemetery in Iowa for her family members but was denied use of them due to their race when one of her relatives died. She sued and won in lower courts before the case reached the Supreme Court which upheld those decisions by ruling that such racial discrimination violated federal civil rights laws even though it involved a privately owned entity rather than government action.

In the dissenting opinion for Rice v. Sioux City Memorial Park Cemetery, Inc., Justice Reed argued that the majority's decision to classify a privately owned cemetery as a public facility was incorrect and overreaching. He contended that this classification imposed an undue burden on private property owners by forcing them to comply with regulations intended for publicly owned facilities. Furthermore, he disagreed with the majority's interpretation of Iowa state law regarding racial discrimination in cemeteries, arguing that it did not apply in this case because the cemetery had always been privately owned and operated. In his view, there was no legal basis for applying public accommodation laws to a private entity like Sioux City Memorial Park Cemetery.