In the case of Yellow Freight System, Inc. v. Donnelly in 1989, the U.S Supreme Court ruled that plaintiffs could bring Title VII employment discrimination lawsuits in any federal court where their employer does business, not just where they work or applied for work. The plaintiff, James P. Donnelly had filed a lawsuit against his former employer Yellow Freight Systems under Title VII of the Civil Rights Act alleging racial discrimination and retaliation at its Chicago Ridge facility in Illinois but brought suit in Kansas City district court because it was more convenient for him to litigate there as he lived nearby. However, Yellow Freight argued that venue was improper since none of the alleged discriminatory acts occurred within that jurisdiction. The District Court dismissed his complaint on grounds of improper venue and this decision was upheld by Tenth Circuit Appeals Court which held that a proper venue is only where an unlawful employment practice is alleged to have been committed. However, upon reaching Supreme Court level review; Justice Thurgood Marshall writing for unanimous bench reversed lower courts' decisions stating "the language and design" of Title VII's provision allows suits wherever respondent has substantial business presence regardless if no significant act related to claim happened there.

In the dissenting opinion for Yellow Freight System, Inc. v. Donnelly, Justice Thurgood Marshall argued that the majority's decision to allow plaintiffs in Title VII cases to seek jury trials and compensatory damages would significantly alter Congress' carefully crafted enforcement scheme under this law. He contended that such a change should be made by Congress itself rather than through judicial interpretation of existing legislation. Furthermore, he expressed concern about potential negative consequences of allowing jury trials in these cases, including an increased burden on federal courts and possible delays or denials of justice for victims of discrimination due to longer trial times and higher litigation costs.