The U.S. Supreme Court case Baltimore Gas & Electric Co. et al v. Natural Resources Defense Council, Inc., 1982 revolved around the issue of nuclear power plant licensing and environmental impact assessments required by the National Environmental Policy Act (NEPA). The Natural Resources Defense Council (NRDC) challenged a rule established by the Nuclear Regulatory Commission that stated no further environmental impact statement was needed after a certain stage in reactor licensing, arguing it violated NEPA's requirements for comprehensive review at every major federal action significantly affecting environment quality. However, the Supreme Court ruled in favor of Baltimore Gas & Electric Co., upholding this "zero-release" assumption as valid under administrative law principles due to agency expertise on technical matters like these being given deference unless clearly erroneous or unsupported by substantial evidence. This decision affirmed agencies' discretion to make predictive judgments within their areas of special expertise.

In the dissenting opinion for Baltimore Gas & Electric Co. v. Natural Resources Defense Council, Inc., Justice Thurgood Marshall argued that the majority had overstepped its role by making a scientific judgment instead of a legal one. He contended that it was not within the Court's purview to decide whether or not nuclear power plants' storage and disposal methods were safe enough to be exempt from environmental impact statements (EIS). Instead, he believed this decision should have been left up to experts in relevant fields such as nuclear physics and engineering who are better equipped with knowledge about these technical issues. Furthermore, he criticized the majority for giving too much deference to administrative agencies like Nuclear Regulatory Commission without properly scrutinizing their decisions against statutory requirements under National Environmental Policy Act (NEPA) which mandates EIS for major federal actions significantly affecting environment quality.