In the 1944 case of Steele v. Louisville & Nashville Railroad Co., the U.S. Supreme Court ruled in favor of African American firemen who claimed that their union, Brotherhood of Locomotive Firemen and Enginemen (BLFE), had violated their rights under the Railway Labor Act by negotiating contracts with discriminatory wage differentials based on race. The court held that a labor organization authorized to represent a craft or class of employees under this act has a duty to represent all members without discrimination because it acts as a statutory representative for collective bargaining purposes. Therefore, BLFE's actions were deemed unlawful due to its failure to equally protect black workers' interests when negotiating employment conditions with railroads. This landmark decision established an important precedent regarding racial equality within unions and set forth principles against racial discrimination in labor representation.

In the dissenting opinion for Steele v. Louisville & Nashville Railroad Co., Justice Roberts argued that the majority's decision was an overreach of judicial power, as it imposed a duty on labor unions not explicitly stated in the Railway Labor Act. He contended that while racial discrimination is morally wrong and should be discouraged, it is not within the Court's authority to impose obligations beyond what Congress has legislated. The Act does not expressly require labor unions to represent all employees equally; therefore, according to Justice Roberts, such a requirement cannot be inferred or enforced by courts without infringing upon legislative powers. Furthermore, he expressed concerns about potential implications of this ruling on other areas where similar issues might arise but are outside of explicit statutory provisions.