In the case of Atlantic Richfield Co. v. USA Petroleum Co., 1989, the U.S Supreme Court ruled in favor of Atlantic Richfield Company (ARCO). The dispute arose when USA Petroleum accused ARCO of engaging in predatory pricing to maintain a monopoly over gasoline sales in certain markets, thereby violating federal antitrust laws. Predatory pricing refers to selling goods or services below cost with an intention to drive competitors out of business and then raise prices later on. However, the court held that for a competitor's claim under these laws to be valid, it must show that it suffered actual injury due directly from illegal conduct by another party; mere potential harm is not enough. In this context, since USA Petroleum was not a consumer but rather a competitor who could potentially benefit from higher prices resulting from ARCO’s alleged actions, they were unable to demonstrate such direct harm and thus their claim was dismissed.

In the dissenting opinion for Atlantic Richfield Co. v. USA Petroleum Co., Justice Stevens, joined by Justices Brennan and Marshall, argued that the majority's decision was inconsistent with both precedent and congressional intent. They contended that a literal interpretation of Section 4 of the Clayton Act would allow any person who is injured in his business or property by reason of anything forbidden in antitrust laws to sue for damages; this includes competitors harmed by predatory pricing schemes like those alleged in this case. The dissent also criticized the majority's reliance on policy arguments about potential floodgates of litigation and chilling effects on price competition as unsupported speculation which should not override clear statutory language and legislative history indicating Congress intended to provide broad access to judicial remedies for antitrust violations.