The U.S. Supreme Court case American Textile Manufacturers Institute, Inc., et al. v. Donovan, Secretary of Labor, et al., 1980 revolved around the Occupational Safety and Health Act (OSHA) standards for cotton dust exposure in textile mills to prevent byssinosis or "brown lung disease". The American Textile Manufacturers Institute challenged OSHA's regulations arguing that they were not economically feasible and did not provide substantial evidence to support their necessity. However, the court ruled in favor of OSHA stating that it was only required to prove a significant risk existed at current industry levels and that its proposed standard would reduce this risk; it didn't need to calculate a precise benefit-cost analysis as argued by the manufacturers' institute. Additionally, economic feasibility was interpreted as whether an industry could absorb or pass on costs without threatening its long-term profitability or competitiveness rather than individual businesses within it being able to afford compliance with new standards.

In the dissenting opinion for American Textile Manufacturers Institute, Inc. v. Donovan, Justice Powell argued that the majority's decision to uphold OSHA's cotton dust standards was a misinterpretation of the Occupational Safety and Health Act (OSHA). He believed that while Congress intended for OSHA to set safety standards based on significant risks, it did not intend for these regulations to be so stringent as to potentially bankrupt an industry or significantly affect its competitiveness. Furthermore, he criticized the majority’s view that cost-benefit analysis is irrelevant under OSHA; instead asserting such analysis should play a role in determining whether a risk is "significant." Finally, he expressed concern over how this ruling could lead to overly strict regulation by other government agencies without proper consideration of economic consequences.