In Bellis v. United States (1973), the Supreme Court ruled that a person cannot use the Fifth Amendment's protection against self-incrimination to avoid producing business records of a dissolved partnership, even if those documents might incriminate them personally. The court held that such records are not personal but belong to the collective entity, and thus do not fall under individual privilege protections. In this case, Mr. Bellis was subpoenaed by a grand jury investigating possible federal gambling law violations and asked for financial books from his former three-person legal practice which had since been dissolved. He refused on grounds it would violate his Fifth Amendment rights as he kept sole possession of these documents after dissolution of the firm.

In the dissenting opinion for Bellis v. United States, Justice Douglas argued that the Fifth Amendment's protection against self-incrimination should extend to collective entities such as partnerships. He contended that compelling a partner to produce partnership records was equivalent to forcing an individual to reveal personal papers, which would be unconstitutional. The majority ruling held that partners in a business do not have a reasonable expectation of privacy regarding partnership records because these documents are considered collective property rather than private possessions. However, Justice Douglas disagreed with this interpretation and believed it undermined individuals' constitutional rights by allowing government intrusion into their private affairs under certain circumstances.