In the United States v. Patterson case of 1893, the U.S. Supreme Court ruled that a federal law prohibiting racial discrimination could not be applied to private individuals or organizations but only to state actions. The case involved an African American man named Robert P. Patterson who was denied service at a hotel in Denver, Colorado due to his race and subsequently sued under the Civil Rights Act of 1875 which prohibited racial discrimination in public accommodations. However, the court held that Congress did not have authority under either the Thirteenth or Fourteenth Amendment to regulate private conduct and therefore dismissed Patterson's claim against Isaac Younts (the hotel owner). This decision significantly limited federal power over civil rights enforcement during this period.

In the dissenting opinion for United States v. Patterson, Justice Brewer argued that the majority's interpretation of the Civil Rights Act was too narrow and failed to protect African Americans from discrimination as intended by Congress. He contended that racial discrimination in jury selection violated both a defendant's personal rights and societal interests in fair trials. The majority’s decision, he believed, undermined these protections by allowing states to discriminate based on race without federal intervention. Furthermore, he disagreed with their view that only state action could violate civil rights laws; private individuals should also be held accountable for such violations. In his view, this case represented an opportunity for the Court to affirm its commitment to equal protection under law but it had instead chosen a path contrary to justice and equality.