The U.S. Supreme Court case Velde, Administrator, Law Enforcement Assistance Administration (LEAA), et al. v. National Black Police Association (NBPA), Inc., et al., 1981 centered around a dispute over federal funding for local law enforcement agencies and the alleged racial discrimination in their hiring practices. The NBPA sued the LEAA arguing that it was illegally providing funds to police departments with discriminatory hiring practices against African Americans and other minorities, violating Title VI of the Civil Rights Act of 1964 which prohibits racial discrimination by recipients of federal financial assistance. The District Court agreed with NBPA but on appeal, the Supreme Court reversed this decision stating that private individuals or organizations do not have standing to sue under Title VI unless they can prove personal injury resulting from such discriminatory conduct.

In the dissenting opinion for Velde v. National Black Police Association, Justice Thurgood Marshall argued that the majority's decision to deny standing to minority police officers was a misinterpretation of precedent and an unjust restriction on access to judicial review. He contended that these officers had demonstrated sufficient "injury in fact" as they were directly affected by discriminatory hiring practices allegedly perpetuated by federal funding. Furthermore, he believed their claims fell within the "zone of interests" protected by Title VI since it aims at eliminating racial discrimination in federally assisted programs. By denying them standing, Marshall feared this would insulate government agencies from legal accountability when violating anti-discrimination laws with their grant-making decisions.