In Dixon v. Coburg Dairy, Inc., the Fourth Circuit held that the district court in South Carolina lacked subject matter jurisdiction to hear an unlawful termination action involving a right to display the Confederate battle flag at work. The May 2004 decision is the latest in a series of opinions on this flag controversy.

For those interested in symbology, Judge Gregory (who authored the first decisions) provides in his concurrence a historical backdrop that details "why coworkers might feel offended, harassed and even threatened by the Confederate battle flag in the workplace, even if those who display the flag do so with no ill will."