The U.S. Supreme Court case Washington et al. v. Seattle School District No. 1 et al., in 1981, revolved around a conflict between the state of Washington and the Seattle School District over desegregation busing policies implemented by the school district to reduce racial imbalance in schools. The State had passed an initiative (Initiative 350) that effectively prohibited such busing programs unless a court order required them due to violation of constitutionally protected rights, which was challenged by the school district as unconstitutional under Equal Protection Clause of Fourteenth Amendment. In its decision, the Supreme Court sided with Seattle School District stating that Initiative 350 violated equal protection principles because it used race as a basis for policy-making and placed obstacles on minority groups' ability to achieve beneficial legislation; thus infringing upon their political process rights.

In the dissenting opinion for Washington v. Seattle School District No. 1, Justice Blackmun argued that the majority misinterpreted and misapplied previous Supreme Court rulings on racial discrimination. He contended that Initiative 350 was not racially neutral as it targeted a policy designed to combat de facto segregation in schools, thus perpetuating racial inequality rather than promoting equal treatment under the law. Furthermore, he disagreed with the majority's view of political restructuring doctrine, arguing that it should apply when a law has both discriminatory intent and impact - which he believed was true for Initiative 350. In his view, this case represented an attempt by white majorities to overturn policies benefiting minorities through changing political structures – something prohibited by precedent cases such as Hunter v. Erickson and Reitman v Mulkey.