In the case of Donald J. Willy v. Coastal Corporation, et al., 1991, attorney Donald J. Willy sued his former employer, Coastal Corporation and its subsidiary ANR Pipeline Company for wrongful termination after he reported violations of federal environmental laws to the Environmental Protection Agency (EPA). The Supreme Court ruled in favor of Coastal Corp., stating that there was no implied private right to sue under the citizen-suit provision of the Resource Conservation and Recovery Act (RCRA), which is a federal law addressing disposal methods for hazardous waste. This decision clarified that only government entities could bring lawsuits under this act's provisions rather than individual citizens or employees who report violations.

In the dissenting opinion for Donald J. Willy v. Coastal Corporation, et al., 1991, it was argued that the majority's decision to dismiss attorney Willy's claim under RICO (Racketeer Influenced and Corrupt Organizations Act) was incorrect. The dissenting justices believed that there were sufficient grounds to consider a pattern of racketeering activity based on allegations of multiple instances of mail fraud by Coastal Corporation in their attempts to manipulate regulatory proceedings against them. They also disagreed with the majority’s interpretation of "enterprise" under RICO, arguing that an enterprise should not be limited only to organizations whose primary purpose is economic gain but could include any entity through which individuals conduct illegal activities - including courts or government agencies manipulated by corrupt parties. Furthermore, they contended that dismissing this case prematurely without allowing discovery or trial would undermine efforts towards judicial transparency and accountability.