The U.S. Supreme Court case Andrus, Secretary of the Interior, et al. v. Sierra Club et al., 1978 revolved around whether or not the Sierra Club was entitled to attorney's fees under section 307(f) of the Clean Air Act and section 204(a)(2) of the Federal Water Pollution Control Act Amendments after they successfully challenged regulations issued by Cecil D. Andrus, then-Secretary of Interior in relation to these acts but did not achieve any substantial alteration in their favor as a result. The court ruled against Sierra Club stating that while both Acts do allow for awarding attorney’s fees when appropriate, it is at discretion of courts and should be based on achieving some degree of success beyond mere procedural victories. The court held that since no significant change resulted from Sierra Club's challenge; hence they were not eligible for fee recovery.

In the dissenting opinion for Andrus v. Sierra Club, Justice William J. Brennan Jr., joined by Justices Thurgood Marshall and Harry Blackmun, argued that the majority misinterpreted the Freedom of Information Act (FOIA). They believed that FOIA's fee waiver provision should be interpreted broadly to promote public access to government information. The dissenters disagreed with the majority’s view that a requester must show potential for contributing significantly to public understanding of government operations or activities in order to qualify for a fee waiver under FOIA. Instead, they held that any request which would benefit the general public interest should be eligible for a fee waiver regardless of whether it specifically pertains to governmental operations or activities.