In the United States v. Stauffer Chemical Co. case of 1983, the Supreme Court ruled in favor of the U.S government against Stauffer Chemical Company regarding a dispute over sulfur rights on federal land. The company had been leasing federally owned lands for mining purposes and argued that they were entitled to all minerals found therein, including sulfur deposits discovered during their operations. However, an earlier law from 1872 stated that only "valuable mineral deposits" could be claimed by private entities while another statute passed in 1920 reserved all oil and gas (and other similar substances) to the U.S government when it sold or leased public lands. The court held that these laws impliedly included sulfur as one such substance reserved for governmental ownership due to its similarity with oil and gas in terms of extraction methods and commercial uses; thus ruling against Stauffer's claim over exclusive rights to mine sulfur on leased federal lands.

In the dissenting opinion for United States v. Stauffer Chemical Co., it was argued that the majority's decision to allow a citizen suit against a company under the Clean Air Act, despite an ongoing enforcement action by the Environmental Protection Agency (EPA), undermined administrative authority and could potentially lead to conflicting court orders. The dissent emphasized that Congress intended for citizens' suits to be supplementary rather than primary enforcement mechanisms, only available when both EPA and state authorities failed to exercise their enforcement responsibilities adequately. It was also pointed out that allowing simultaneous actions might discourage government agencies from taking on complex cases if they knew private litigants could intervene at any time. Furthermore, this interpretation of law would encourage "overlapping litigation," which is generally disfavored due to its inefficiency and potential for inconsistent results.