In the 1980 case Monroe v. Standard Oil Co., the United States Supreme Court addressed whether an employer could be held liable under federal law for a work-related injury that was not covered by state workers' compensation laws. The plaintiff, Monroe, had developed leukemia as a result of exposure to benzene in his workplace at Standard Oil Company and sought damages from his employer under maritime law since Ohio’s worker's compensation did not cover occupational diseases at that time. However, the court ruled against him stating that when Congress enacted comprehensive legislation to provide benefits for injured workers (the Longshoremen's and Harbor Workers' Compensation Act), it intended this act to be an exclusive remedy replacing all other rights and remedies under federal maritime law or any other jurisdiction. Therefore, even though Monroe couldn't receive benefits through Ohio’s worker's compensation system due to its limitations on coverage of occupational diseases, he also couldn't seek relief through alternative legal avenues such as federal maritime law.

In the dissenting opinion for Monroe v. Standard Oil Co., the justice disagreed with the majority's interpretation of Section 4 of Clayton Act, arguing that it was too narrow and restrictive. The justice believed that this section should be interpreted to allow any person who is injured in their business or property by reason of anything forbidden in antitrust laws to sue for damages. This includes indirect purchasers like Monroe, who suffered from higher prices due to alleged price-fixing conspiracy among oil companies even though they did not directly purchase from these companies. The dissent argued that denying such individuals a cause of action would undermine the deterrent effect and compensatory purpose of antitrust laws as well as contradict Congress' intent when enacting them.