In the case of Thunder Basin Coal Company v. Robert B. Reich, Secretary of Labor et al., 1993, the U.S. Supreme Court ruled in favor of the Secretary of Labor and against Thunder Basin Coal Company (TBCC). TBCC had challenged a regulation by Mine Safety and Health Administration (MSHA) that allowed miners' representatives to be paid while they performed certain duties related to safety enforcement on company time. The court held that TBCC must first challenge this rule through administrative channels before seeking judicial review because Congress intended for such disputes to be resolved within an established statutory review scheme under Federal Mine Safety and Health Amendments Act (FMSHAA). This decision reinforced the principle that companies cannot bypass administrative procedures unless there are adequate reasons demonstrating these procedures are incapable or inappropriate for resolving their claims.

In the dissenting opinion for Thunder Basin Coal Company v. Robert B. Reich, Justice Scalia argued that the Federal Mine Safety and Health Amendments Act of 1977 does not preclude district court jurisdiction over constitutional claims. He contended that the majority's interpretation was overly broad and would effectively bar any miner or operator from bringing a constitutional challenge to an order issued under this act in district court before exhausting all administrative remedies, which could take years. This, he believed, would be inconsistent with Congress' intent when it passed legislation allowing immediate judicial review of such orders in certain circumstances. Furthermore, he disagreed with the majority's view that Thunder Basin had ample opportunity to raise its objections during administrative proceedings; instead asserting these procedures were inadequate for resolving complex constitutional issues like those raised by Thunder Basin.