In the case of Rizzo, Mayor of Philadelphia, et al. v. Goode et al., 1975, a group of African American and Hispanic residents filed a lawsuit against the city's mayor and other officials alleging widespread discriminatory practices by police officers in Philadelphia. The plaintiffs sought an injunction to prevent future misconduct by law enforcement personnel based on evidence from past incidents involving racial discrimination and abuse of power. However, the Supreme Court ruled in favor of Mayor Frank Rizzo and his co-defendants with a 6-3 decision stating that federal courts should not intervene in local government operations unless there is proof that those officials are directly responsible for constitutional violations or have failed to act despite knowledge about such transgressions. The court found no clear pattern linking these isolated instances to policies endorsed or tolerated by top city authorities thus concluding insufficient grounds for systemic reform through judicial intervention.

In the dissenting opinion for Rizzo v. Goode, Justice Brennan argued that the majority's decision to dismiss the case was premature and failed to address systemic issues of police misconduct in Philadelphia. He contended that there were sufficient allegations of a pattern or practice of unconstitutional conduct by city officials which warranted judicial intervention under federal civil rights laws. The dismissal, according to him, ignored substantial evidence demonstrating an ongoing failure by city authorities to properly supervise and discipline police officers involved in racial discrimination and abuse cases against citizens. This lack of action effectively condoned such behavior, thus violating constitutional rights protected under federal law. Furthermore, he criticized the majority's narrow interpretation of "appropriate relief", arguing it should include any measures necessary to prevent future violations rather than just remedying past harm.