In the case of Brock, Secretary of Labor, et al. v. Roadway Express, Inc., 1986, the U.S. Supreme Court ruled that a federal agency has the authority to seek punitive damages for violations committed by an employer against its employees under certain circumstances. The Department of Labor had filed suit against Roadway Express on behalf of several employees who were allegedly discharged or otherwise discriminated against for filing safety complaints with OSHA (Occupational Safety and Health Administration). The court held that while Congress did not explicitly provide for punitive damages in this context within the Occupational Safety and Health Act itself, it was implied through other statutory language that such remedies could be pursued when necessary to ensure compliance with workplace safety standards.

In the dissenting opinion of Brock v. Roadway Express, Inc., Justice White argued that the majority's decision to allow punitive damages under Section 11(c) of the Occupational Safety and Health Act (OSHA) was not supported by legislative history or statutory language. He contended that Congress did not intend for punitive damages to be awarded in these cases, as it had explicitly provided for such penalties in other statutes but not within OSHA. Furthermore, he expressed concern about potential excessive awards resulting from this interpretation and suggested that compensatory damages would sufficiently deter violations without risking disproportionate punishment. Lastly, Justice White disagreed with the majority’s assertion that Secretary of Labor has authority to sue for employee reinstatement and backpay on behalf of employees; instead he believed individual employees should bring their own actions.