The Supreme Court case Sheet Metal Workers' International Association et al. v. Lynn in 1988 centered around a dispute over the legality of affirmative action plans imposed by courts on unions that had been found guilty of racial discrimination. The union argued that such court-ordered plans violated their rights under Title VII of the Civil Rights Act, which prohibits employment discrimination based on race, color, religion, sex and national origin. However, the Supreme Court ruled against them with a 5-4 decision stating that these remedial measures were necessary to combat past discriminatory practices and did not violate Title VII or infringe upon non-minority workers’ rights as they only temporarily limited those rights while serving a greater public interest in eradicating racial discrimination.

In the dissenting opinion for Sheet Metal Workers' International Association et al. v. Lynn, Justice White disagreed with the majority's decision to uphold a lower court order requiring union locals to merge in order to remedy past racial discrimination. He argued that such an extreme measure was not justified by the evidence presented and exceeded what was necessary or appropriate under Title VII of the Civil Rights Act of 1964, which prohibits employment discrimination based on race, color, religion, sex and national origin. Furthermore, he contended that this ruling could potentially lead unions to avoid admitting minority members altogether out of fear they would be forced into similar drastic measures if found guilty of discrimination in future cases.