The U.S. Supreme Court case Barbara Landgraf v. USI Film Products et al., 1993, revolved around the issue of whether provisions in the Civil Rights Act of 1991 could be applied retroactively to cases that were pending when the act was passed. The plaintiff, Barbara Landgraf, had filed a sexual harassment lawsuit against her employer prior to this law's enactment and sought compensatory damages under its new provisions after it came into effect. However, her employer argued that these changes should not apply retrospectively as they were not explicitly stated in the legislation itself. The Supreme Court ruled in favor of USI Film Products by holding that unless Congress clearly states otherwise within a statute’s text or historical context, federal laws will not apply retroactively to events predating their enactment if doing so would infringe upon or impair rights a party possessed when he acted; increase his liability for past conduct; or impose new duties with respect to transactions already completed.

The dissenting opinion in the case of Barbara Landgraf v. USI Film Products et al., argued that the Civil Rights Act of 1991 should be applied retroactively to cases pending at the time it was enacted. The dissent, led by Justice Blackmun, contended that Congress intended for this law to apply to all cases not yet final when it passed. This interpretation is based on a provision within the act itself which states that it applies to all proceedings pending on or after its enactment date. Furthermore, they argued that applying new rules in ongoing lawsuits does not violate due process rights as long as those changes are procedural and do not alter substantive rights or obligations; here, allowing compensatory damages under Title VII merely changed remedies available rather than altering any party's liability or defenses.