In the case of Brock, Secretary of Labor v. Pierce County (1985), the U.S. Supreme Court ruled that a federal agency has no inherent authority to reclaim funds from a grantee after the statutory period for recovery has passed, unless it is expressly provided by statute or contractually reserved right. The Department of Labor had sought to recover alleged misused Comprehensive Employment and Training Act (CETA) funds from Pierce County in Washington State several years after they were disbursed and used. However, because there was no explicit provision allowing such action within CETA's legislation or in any agreement between parties involved, and since the time limit for taking corrective action had expired under CETA regulations before proceedings began against Pierce County; therefore, according to Justice Thurgood Marshall who delivered the opinion of court on this matter -the Department lacked authority to demand repayment.

In the dissenting opinion for Brock, Secretary of Labor v. Pierce County, Justice White disagreed with the majority's interpretation that a statute of limitations should apply to government enforcement actions. He argued that this decision could potentially hinder public officials from performing their duties effectively and efficiently. Furthermore, he expressed concern about how such an interpretation might affect other federal statutes where Congress has not explicitly set a time limit for enforcement actions by governmental agencies. In his view, it was not appropriate or necessary to impose judicially created deadlines on these types of proceedings when there is no clear legislative intent indicating that such limits should exist.