The Bates v. City of Little Rock case in 1959 revolved around the issue of whether cities could require organizations to disclose their membership lists as a condition for operating within city limits. The Supreme Court ruled in favor of Daisy and L.C. Bates, leaders of the local chapter of the National Association for Advancement Colored People (NAACP), who had refused to provide such information to Little Rock, Arkansas officials on grounds that it violated their First Amendment rights. The court held that compulsory disclosure by these groups posed substantial restraints on freedom-of-association rights protected under the Constitution's First Amendment and Fourteenth Amendments' due process clause without sufficient justification from government interests; hence was unconstitutional.

In the dissenting opinion for Bates et al. v. City of Little Rock et al., Justice Frankfurter, joined by Justice Clark and Justice Whittaker, argued that the majority had overstepped its bounds in striking down a local ordinance requiring disclosure of membership lists from organizations like NAACP as it was not inherently unconstitutional. They contended that such ordinances could serve legitimate purposes related to taxation or regulation of activities within a city's jurisdiction. The dissenters believed that whether this particular application infringed upon constitutional rights should have been left to state courts to decide first before Supreme Court intervention. They also expressed concern about potential misuse of judicial power and warned against using broad strokes when dealing with complex issues involving both individual liberties and societal interests.