In the United States v. Paradise et al., 1986, the U.S. Supreme Court upheld a district court's order that required Alabama Department of Public Safety (DPS) to promote one black trooper for every white trooper until half of the positions were filled by African Americans. The case arose from a longstanding racial discrimination issue within DPS which had never promoted an African American above entry level since its establishment in 1935. Despite previous orders to end discriminatory practices, no significant changes occurred leading to this drastic remedy being imposed by lower courts and affirmed by the Supreme Court with a narrow 5-4 majority decision. The court ruled that such race-conscious relief was necessary and appropriate due to persistent non-compliance with anti-discrimination laws and mandates over many years.

In the dissenting opinion for United States v. Paradise et al., Justice William H. Rehnquist, joined by Chief Justice Warren E. Burger and Justice Sandra Day O'Connor, argued that the court-ordered racial quota system was not a narrowly tailored remedy to address past discrimination within Alabama's Department of Public Safety (DPS). The dissenters believed that such an extreme measure should only be used as a last resort when other remedies have failed or are deemed inadequate; they did not believe this threshold had been met in this case. They also expressed concern about potential reverse discrimination against white candidates who were now being passed over solely due to their race under the new quota system, which required 50% of promotions go to black troopers until they made up at least 25% of all ranks within DPS. Furthermore, they disagreed with the majority's assertion that there was no less intrusive way to achieve racial balance quickly in DPS' upper ranks because it overlooked alternative solutions like targeted recruitment or stricter enforcement of anti-discrimination laws.