In the case of Upham et al. v. Seamon et al., 1981, the U.S. Supreme Court ruled that a district court had overstepped its authority by imposing an interim redistricting plan for Texas's state legislature without giving proper deference to the original plan proposed by the state itself. The dispute arose after Texas's initial redistricting proposal was rejected under Section 5 of the Voting Rights Act due to concerns about racial discrimination in voting practices. However, instead of making minimal changes necessary to bring it into compliance with federal law, as is customary when remedying such violations, the district court created and imposed its own comprehensive alternative plan which significantly altered many districts across Texas beyond what was required to address specific legal issues identified in certain areas only.

In the dissenting opinion for Upham et al. v. Seamon et al., Justice Thurgood Marshall, joined by Justices Brennan and Blackmun, argued that the majority's decision to overturn a district court's remedial redistricting plan was incorrect because it failed to give proper deference to the lower court’s judgment. The dissenters believed that there was no clear error in the District Court’s findings of fact or its application of legal principles which would justify such an intervention from Supreme Court. They also pointed out that this case involved complex issues related to racial discrimination in voting practices, where local courts are often better positioned than Supreme Court due their proximity and familiarity with local conditions and history. Furthermore, they criticized the majority for not providing any guidance on what kind of remedy would be acceptable if Texas continued its discriminatory practices in future elections.