The case of Michael C. Antonelli v. Dale Caridine et al., 1999, revolved around the issue of whether a party who has been granted summary judgment on an affirmative defense can seek attorney's fees under Federal Rule of Civil Procedure 54(d)(2). The petitioner, Michael C. Antonelli, had sued several parties for alleged violations of federal securities laws and related state claims but lost his case when the district court granted summary judgment in favor of the defendants based on their statute-of-limitations defense. Subsequently, one defendant sought to recover attorney’s fees under Rule 54(d)(2), which allows such recovery if it is provided by law or agreed upon by the parties involved. Antonelli argued that this rule did not apply because he believed that only prevailing plaintiffs could be awarded attorney's fees in cases involving implied private rights actions under federal securities laws; however, both lower courts disagreed with him. Upon reaching Supreme Court review though, it was held that a party need not prevail on all issues to qualify as a "prevailing party" eligible for fee shifting under Rule 54(d)(2). Therefore, even though they were defendants who won based on an affirmative defense (statute-of-limitations), they were still considered prevailing parties and thus entitled to seek attorneys' fees.

The dissenting opinion in the case of Michael C. Antonelli v. Dale Caridine et al., 1999, argued that the majority's decision to uphold a lower court ruling against Antonelli was incorrect because it failed to consider an important aspect of securities law: materiality. The dissenters believed that for a statement or omission to be considered fraudulent under securities law, it must be materially misleading - meaning that there is a substantial likelihood that its disclosure would have altered the total mix of information available and thus influenced an investor’s decision-making process. In this case, they felt there was insufficient evidence presented at trial proving materiality; therefore, Antonelli should not have been found guilty on charges related to fraudulently inducing investors into purchasing unregistered securities.