The U.S. Supreme Court case Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc., et al., 1977 revolved around the construction of a nuclear power plant by the Vermont Yankee Nuclear Power Corporation (VYNPC). The Natural Resources Defense Council (NRDC) challenged VYNPC's license to construct and operate the plant, arguing that they had not complied with certain procedural requirements under the National Environmental Policy Act (NEPA). The NRDC claimed that NEPA required an agency to explore all possible alternatives in its environmental impact statement and hold formal hearings on unresolved issues related to environmental concerns. However, in a unanimous decision, the Supreme Court ruled in favor of VYNPC stating that courts cannot impose additional procedural requirements beyond those explicitly stated by Congress or mandated by due process. It held that while agencies are free to adopt their own procedures as long as they conform with statutory purposes and constitutional standards, courts should not second-guess these decisions unless there is clear evidence of arbitrary action or abuse of discretion.

The dissenting opinion in the Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc., et al., case argued that the majority's decision was a departure from established administrative law principles and an unwarranted intrusion into agency discretion. The dissent contended that agencies should be allowed to make their own procedural rules as long as they are within legal bounds and not arbitrary or capricious. They also expressed concern about the potential for this ruling to stifle innovation in rulemaking procedures by discouraging experimentation with new methods of public participation or information gathering out of fear of judicial disapproval. Furthermore, they disagreed with the majority's view on NEPA’s role, arguing it is meant to ensure environmental considerations are integrated into government decisions at all levels rather than merely providing full disclosure.