In the 1989 case of Olaf A. Hallstrom, et ux. v. Tillamook County, the U.S Supreme Court ruled that plaintiffs must comply with a statutory requirement to provide 60-days notice before filing a lawsuit under the Resource Conservation and Recovery Act (RCRA). The Hallstroms had filed suit against Tillamook County without providing this notice for alleged violations related to an illegal landfill operation near their home in Oregon. The District Court dismissed their claim due to failure to give prior notice as required by RCRA, but the Ninth Circuit reversed this decision arguing that such requirements were not mandatory if "the goals of RCRA would be better served" by immediate action. However, upon reaching the Supreme Court, it was held unanimously that these pre-suit notification rules are indeed compulsory and cannot be disregarded at discretion of lower courts or litigants themselves.

In the dissenting opinion for Hallstrom v. Tillamook County, Justice White disagreed with the majority's interpretation of the Resource Conservation and Recovery Act (RCRA). He argued that a strict reading of RCRA’s 60-day notice requirement was not necessary to achieve Congress’ intent behind this legislation. The purpose of this provision was to give alleged violators an opportunity to bring themselves into compliance before being sued, which could still be achieved even if plaintiffs filed their lawsuit before providing notice but waited 60 days before serving defendants. Moreover, he pointed out that nothing in RCRA suggests noncompliance should result in automatic dismissal without leave to amend or cure defects after filing suit. Therefore, he believed that such harsh consequences were unwarranted and inconsistent with both legislative intent and general principles governing procedural defaults.