In the case of Ricci v. Chicago Mercantile Exchange et al., 1972, the U.S Supreme Court dealt with a dispute involving securities law and private rights of action. The plaintiff, Albert J. Ricci, was a member of the Chicago Mercantile Exchange (CME) who alleged that CME's Board manipulated soybean futures prices for their personal benefit in violation of Commodity Exchange Act (CEA). He sought damages on behalf his fellow members under Section 4b of CEA which prohibits price manipulation but does not explicitly provide for private lawsuits. The District Court dismissed his claim stating that he lacked standing to sue because he did not personally suffer any injury from the alleged manipulation. On appeal, Seventh Circuit reversed this decision arguing that Congress intended to allow such suits even if they were not expressly mentioned in CEA. However, upon reaching Supreme Court it held that there is no implied right to sue under Section 4b unless one can show direct harm resulting from violations. It further stated that allowing such broad interpretation would lead to excessive litigation undermining regulatory framework established by Congress through Commodity Futures Trading Commission (CFTC). Therefore it overturned Seventh Circuit’s ruling reinstating original dismissal.

In the dissenting opinion for the Ricci v. Chicago Mercantile Exchange case, it was argued that the majority's decision failed to adequately consider and protect individual rights against collective action. The dissenters believed that there were significant issues with how the exchange handled disciplinary proceedings, particularly in terms of due process protections. They contended that these procedures did not meet minimum constitutional standards because they allowed a group of competitors to essentially judge one another without sufficient oversight or impartiality. Furthermore, they disagreed with the majority's assertion that exchanges are private entities immune from constitutional scrutiny; instead, they viewed them as quasi-public institutions given their regulatory functions and impact on public interest. Therefore, according to this perspective, exchanges should be held accountable under federal law when their actions infringe upon individuals' rights.