The U.S. Supreme Court case System Federation No. 91, Railway Employes' Department, AFL-CIO v. Wright et al., revolved around a labor dispute between the Brotherhood of Locomotive Firemen and Enginemen (BLFE) and several railroad companies in Memphis, Tennessee. The BLFE had been ordered by a federal district court to stop discriminating against non-white workers in its membership policies as part of an earlier consent decree; however, the union continued to violate this order by refusing black employees full membership rights while still collecting dues from them. In response to these ongoing violations, the district court held the union in contempt and imposed fines until it complied with its original order. In their appeal before the Supreme Court, representatives for BLFE argued that they were not bound by previous rulings because those decisions did not explicitly state that all forms of racial discrimination were prohibited under federal law at that time. However, this argument was rejected unanimously by all nine justices on grounds that any form of racial discrimination is inherently illegal under both statutory law (i.e., written laws passed by legislative bodies) and common law (i.e., legal principles developed through judicial decisions). Therefore, regardless whether specific types or instances of discriminatory behavior are mentioned directly within existing legislation or case precedents themselves does not exempt parties from being legally obligated to refrain from engaging such conduct altogether.

In the dissenting opinion for SYSTEM FEDERATION NO. 91, RAILWAY EMPLOYES' DEPARTMENT, AFL-CIO, et al. v. WRIGHT et al., Justice Frankfurter argued that the Court had overstepped its boundaries by intervening in a labor dispute and imposing an agreement on both parties involved. He contended that this was not within their jurisdiction or power as defined by the Railway Labor Act (RLA). The RLA was designed to encourage collective bargaining and prevent strikes but did not give courts authority to enforce specific terms of employment contracts or agreements between unions and employers. Furthermore, he believed it violated principles of federalism because state law should govern such disputes unless explicitly overridden by Congress - which it hadn't been in this case.