In the case of Walker v. Southern Railway Co., 1966, the U.S Supreme Court addressed a dispute over racial discrimination in employment practices. The plaintiff, an African American railroad worker named Bruce Boynton, claimed that he was unjustly fired from his job due to his race and involvement in civil rights activities. He argued that this violated Title VII of the Civil Rights Act of 1964 which prohibits employers from discriminating against employees on the basis of sex, race, color, national origin or religion. The defendant company contended they had dismissed him for insubordination and not because he was black or involved with civil rights activism. They also challenged whether Title VII could be applied retroactively to cover actions taken before it became law. The court ruled in favor of Boynton stating that there was sufficient evidence showing discriminatory intent behind his dismissal by Southern Railway Company. It held that while Title VII does not apply retroactively generally; it can be used as a standard to judge if an employer's conduct is discriminatory when deciding cases about dismissals after its enactment.

In the dissenting opinion for Walker v. Southern Railway Co., Justice Black disagreed with the majority's ruling that a federal court could not hear a case involving an injured railway worker because of lack of diversity jurisdiction. He argued that Congress, in passing the Federal Employers' Liability Act (FELA), intended to provide railroad workers with access to federal courts regardless of their state citizenship or where they were injured. The majority’s interpretation, he contended, would deny many workers this right and force them into potentially biased state courts due to their employer's influence within those jurisdictions. Furthermore, he believed it was inappropriate for the Court to rely on legislative history when interpreting FELA as it should be interpreted based on its plain language and purpose - which is providing broad protection for railroad workers.