In the case of Baldrige, Secretary of Commerce, et al. v. Shapiro, Essex County Executive (1981), Robert Shapiro requested detailed statistical data from the 1980 Census for specific geographic areas within his jurisdiction in order to challenge the census count's accuracy. The U.S. Department of Commerce refused this request citing Title 13 which prohibits disclosure that could identify individual respondents or provide identifiable information about them. The Supreme Court ruled in favor of Baldrige and against Shapiro with a majority decision stating that Congress intended to protect privacy when it enacted Title 13 and its prohibition on revealing individually identifiable responses collected during a census survey outweighed any state interest in reviewing such records for purposes related to ensuring accurate representation.

In the dissenting opinion for Baldridge v. Shapiro, Justice Thurgood Marshall argued that the majority's decision to uphold a confidentiality statute preventing disclosure of raw census data was incorrect and overly broad in its interpretation. He contended that this ruling would potentially allow government agencies to withhold information from public scrutiny under the guise of confidentiality, thereby undermining transparency and accountability. Furthermore, he disagreed with the majority's view on how much deference should be given to administrative interpretations of statutes like those at issue here. In his view, courts should not simply accept an agency’s interpretation without conducting their own analysis first; they must ensure it aligns with congressional intent behind such laws before accepting them as valid.