In Barenblatt v. United States, the U.S. Supreme Court upheld a conviction of contempt of Congress against Lloyd Barenblatt, a former university professor who refused to answer questions about his alleged Communist affiliations during hearings conducted by the House Un-American Activities Committee (HUAC). The court ruled in 1958 that Congressional inquiries into an individual's association with the Communist Party were within its jurisdiction as they pertained to potential legislative action and did not infringe upon First Amendment rights. This decision was based on balancing the need for national security against constitutional freedoms. It held that while freedom of speech is important, it is not absolute when weighed against significant governmental interests such as protecting itself from overthrow or subversion.

In the dissenting opinion for Barenblatt v. United States, Justice Hugo Black argued that the majority's decision violated Barenblatt's First Amendment rights to freedom of speech and assembly. He contended that Congress had overstepped its bounds by investigating individual beliefs and associations without a clear legislative purpose. According to Black, this type of investigation was akin to establishing an inquisition into people’s thoughts which he believed was not within Congressional power as it could lead to abuse and oppression. Furthermore, he disagreed with the majority's interpretation of "pertinency," arguing that such broad interpretation allowed Congress almost unlimited investigative authority which threatened civil liberties. He also criticized the Court for failing to provide adequate protection against potential abuses of power by Congress.