In Bryson v. United States, the Supreme Court ruled that a person cannot defend against a charge of filing false statements with the government by arguing that they were not legally obligated to file any statement at all. The case involved union officials who had falsely claimed in affidavits submitted to the National Labor Relations Board (NLRB) that their organization was not controlled by communists. They argued these falsehoods should be excused because anti-communist regulations violated their First Amendment rights and thus they shouldn't have been required to submit such affidavits in the first place. However, Justice Hugo Black wrote for a unanimous court stating "Our legal system provides methods for challenging the Government's right to ask questions—lying is not one of them." Therefore, even if an individual believes a law or regulation requiring disclosure is unconstitutional, it does not give them license to lie on official documents without facing potential penalties.

In the dissenting opinion for Bryson v. United States, Justice Black argued that the majority's decision to uphold Bryson's conviction was a violation of his First Amendment rights. He contended that by criminalizing false statements made in non-compulsory union membership questionnaires, the court had effectively sanctioned government intrusion into private affairs and chilled free speech. Furthermore, he asserted that such an interpretation of Section 1001 could potentially lead to its misuse as a catch-all offense against any form of dishonesty or misrepresentation towards the government - something it was not intended for. Thus, according to Justice Black’s dissenting view, this ruling set a dangerous precedent which threatened individual liberties and constitutional safeguards.