In the case of Ruckelshaus v. Sierra Club (1982), the U.S. Supreme Court ruled that, under the Clean Air Act, attorney's fees could not be awarded to a party simply because they had catalyzed policy change or contributed to public interest; rather, it was necessary for them to have "prevailed" in their litigation efforts. The Sierra Club had sued the Environmental Protection Agency (EPA) over its implementation of certain provisions within the Clean Air Act and sought reimbursement for legal expenses despite not having won on any significant issue in court nor achieved any direct benefit from their lawsuit. The Supreme Court held that Congress intended to limit awards of attorney’s fees under this act only when parties achieve some success on substantive issues - meaning they must at least achieve some material alteration of the legal relationship between parties involved.

In the dissenting opinion for Ruckelshaus v. Sierra Club, Justice Blackmun argued that the majority's decision to deny attorney's fees to the Sierra Club was inconsistent with both precedent and congressional intent. He contended that Congress intended for courts to award attorney’s fees when a lawsuit resulted in benefits for the public, even if it did not result in a court-ordered change in behavior. In this case, he believed that Sierra Club’s suit had prompted voluntary action by EPA which benefited public interest and therefore they should be awarded their legal costs. Furthermore, he criticized the majority's interpretation of "prevailing party," stating it was too narrow and failed to consider situations where lawsuits lead indirectly but significantly towards achieving litigation goals without formal judicial recognition or relief.