In the case of Block, Secretary of Agriculture, et al. v. Neal in 1982, the U.S Supreme Court ruled that a federal statute did not allow private individuals to sue for damages caused by alleged violations of regulations set forth by the Farmers Home Administration (FmHA). The plaintiff, Mrs. Neal had taken out two loans from FmHA and claimed that she was not informed about certain rights regarding loan servicing options which could have prevented her foreclosure. She sued for emotional distress and other damages resulting from this lack of information on part of FmHA officials. The court held that while it is true these regulations were designed to benefit borrowers like Mrs.Neal, they do not automatically create enforceable duties under federal law unless Congress intended them to be mandatory rather than discretionary guidelines for agency action. Therefore since there was no clear intent shown by Congress in this regard when enacting the Housing Act or its amendments allowing such lawsuits against government officials who violate these rules; Mrs.Neal's claim was dismissed.

In the dissenting opinion for Block, Secretary of Agriculture, et al. v. Neal (1982), Justice O'Connor disagreed with the majority's interpretation of Section 502(c) of the Housing Act and argued that it should not be read to provide a private cause of action for damages resulting from procedural violations by federal agencies. She contended that Congress did not intend to create such an expansive remedy when they enacted this law, as evidenced by its legislative history and context within the broader statutory scheme. Furthermore, she believed that allowing individuals to sue federal agencies over procedural errors could lead to excessive litigation and hinder their ability to perform essential functions effectively. Thus, in her view, any grievances against agency procedures should be addressed through administrative channels or other existing legal remedies rather than creating new ones through judicial interpretation.