In the 1993 case of Maurice Rivers and Robert C. Davison v. Roadway Express, Inc., the U.S Supreme Court addressed issues related to racial discrimination in employment practices. The plaintiffs, both African-American employees at Roadway Express, alleged that they were subjected to a racially hostile work environment which included racial slurs and graffiti. They claimed this violated Title VII of the Civil Rights Act of 1964, which prohibits employers from discriminating against employees on the basis of race or color among other things. However, their claims were initially dismissed by lower courts because they failed to file complaints within 180 days after each discriminatory act as required under Title VII's statute limitations period. The Supreme Court reversed these decisions stating that if an employee continues to be exposed to ongoing discrimination then each individual act constitutes a separate actionable unlawful employment practice for which charges can be filed within 180 days thereafter; thus making it possible for victims who have been enduring such conditions over extended periods without filing timely complaints still eligible for relief under Title VII.

In the dissenting opinion for Maurice Rivers and Robert C. Davison v. Roadway Express, Inc., Justice Clarence Thomas argued that the majority's decision to allow punitive damages in cases of racial discrimination under Section 1981 was not supported by historical evidence or precedent. He contended that at the time of its enactment, Section 1981 did not provide for punitive damages and there is no indication Congress intended such a remedy when it revised this law in 1991. Furthermore, he pointed out that allowing punitive damages could potentially lead to excessive awards which would be inconsistent with traditional principles of justice and fairness. In his view, compensatory damages should suffice as they adequately address any harm suffered by victims of racial discrimination.