In the case of Federal Trade Commission (FTC) et al. v. Standard Oil Company of California, the Supreme Court ruled in favor of Standard Oil Co., stating that a company under investigation by a government agency does not have the right to judicial review before any formal action is taken by said agency. The FTC had issued a complaint against Standard Oil alleging violation of antitrust laws but had not yet initiated enforcement proceedings when Standard Oil sought an injunction and declaratory relief from federal courts arguing that FTC's allegations were unfounded and its reputation was being damaged unjustly. However, the court held that such complaints are merely steps in deliberation process leading potentially to adjudication, they do not constitute 'final agency action' as per Administrative Procedure Act (APA), thus cannot be reviewed prematurely by courts.

In the dissenting opinion for Federal Trade Commission v. Standard Oil Company of California, Justice Powell argued that the majority had expanded the concept of "final agency action" too far and in doing so, blurred the line between judicial and administrative functions. He contended that a complaint issued by an administrative agency is not a final action because it does not determine any rights or obligations nor impose any legal consequences. Instead, he viewed it as merely initiating proceedings which may eventually lead to such determinations. Therefore, according to him, these complaints should not be subject to immediate judicial review under the Administrative Procedure Act (APA). He also expressed concern about burdening courts with premature challenges to administrative actions and potentially delaying resolution of disputes within agencies' expertise.