In Watson et al. v. City of Memphis et al., the U.S Supreme Court ruled that municipal parks in Memphis, Tennessee could not be segregated based on race and must be immediately desegregated, rejecting the city's "gradual adjustment" plan for integration. The court held that racial segregation was unconstitutional under the Equal Protection Clause of the Fourteenth Amendment and rejected any delay in implementing this constitutional right to equal protection under law. This decision reinforced previous rulings against racial segregation such as Brown v Board of Education (1954) which had declared state laws establishing separate public schools for black and white students to be unconstitutional, emphasizing immediate compliance with these decisions rather than gradual implementation.

In the dissenting opinion for Watson et al. v. City of Memphis et al., Justice Harlan argued that the majority's decision to mandate immediate desegregation was an overreach of judicial power, as it did not respect local authorities' efforts to achieve racial integration gradually and peacefully. He emphasized that while he agreed with the principle of ending segregation, he believed in a more cautious approach that would allow communities time to adjust and prevent potential social unrest or violence. Harlan also criticized the majority for ignoring previous Supreme Court rulings which allowed gradual desegregation under certain circumstances, arguing this inconsistency undermined legal stability and predictability. Furthermore, he expressed concern about federal courts becoming too involved in local affairs by dictating specific timelines or methods for achieving desegregation.