The United States Supreme Court case of United States v. Pennsylvania Industrial Chemical Corp., 1972, centered around the interpretation and application of the Refuse Act of 1899, which prohibits discharging refuse matter into navigable waters without a permit. The Pennsylvania Industrial Chemical Corporation (PICCO) was convicted for violating this act by discharging industrial waste from its plant into the Monongahela River without a permit. PICCO appealed on grounds that it had been operating under state permits allowing such discharge and argued that "refuse" in context should not include all industrial wastes but only those harmful to navigation. However, the Supreme Court upheld PICCO's conviction stating that Congress intended to prohibit all unauthorized deposits in navigable waters when they enacted the Refuse Act. The court also clarified that obtaining permission from state authorities does not exempt one from federal regulations or penalties under federal law.

In the dissenting opinion for United States v. Pennsylvania Industrial Chemical Corp., Justice William O. Douglas argued that the majority's interpretation of "refuse matter" in the Refuse Act was too broad and could potentially criminalize innocent acts such as a child throwing a candy wrapper into a river. He contended that Congress intended to regulate only industrial waste, not all forms of refuse, and therefore disagreed with the majority's decision to uphold PICC’s conviction for discharging industrial wastes into navigable waters without permit from Army Corps of Engineers under Rivers and Harbors Appropriation Act (Refuse Act) of 1899. Furthermore, he expressed concern about potential overreach by federal agencies if they were given unchecked power to define what constitutes "refuse." In his view, this case represented an instance where administrative discretion had been used excessively and unjustly against corporations.