In the case of Watt, Secretary of the Interior, et al. v. Energy Action Educational Foundation et al., 1981, the U.S Supreme Court ruled in favor of James G. Watt, who was serving as Secretary of the Interior at that time. The issue revolved around whether or not he had overstepped his authority by implementing a policy to expedite leasing for coal mining on federal lands without conducting an environmental impact study under Section 102(2)(C) of National Environmental Policy Act (NEPA). The court held that NEPA did not require an environmental impact statement before adopting a major federal action which altered prior policies concerning public land use; instead it only required such statements "to the fullest extent possible". Therefore, since there were no specific statutory mandates requiring him to conduct these studies before changing this policy and because he had considered environmental factors during decision-making process as per Administrative Procedure Act (APA), his actions were deemed lawful.

In the dissenting opinion for Watt v. Energy Action Educational Foundation, Justice Thurgood Marshall argued that the majority's decision to uphold the Secretary of Interior's authority to lease federal lands for coal mining without considering environmental factors was a misinterpretation of both legislative intent and statutory language. He contended that Congress intended for an extensive review process before leasing decisions were made, including consideration of environmental impacts as required by National Environmental Policy Act (NEPA). Furthermore, he disagreed with the majority’s view on "consent" in relation to state participation in land use planning processes. According to him, states should have more than just advisory roles; they should be able to veto proposed leases if they believe it would adversely affect their environment or citizens' welfare. Lastly, he criticized the court’s deference towards administrative agencies’ interpretation over clear congressional mandates.