In the case Church of Scientology of California v. United States and Frank S. Zolin, 1992, the U.S Supreme Court ruled on issues related to attorney-client privilege and crime-fraud exception in relation to taped conversations between church officials and their lawyers. The Internal Revenue Service (IRS) sought these tapes as part of an investigation into alleged criminal activities by the Church. The Church argued that these tapes were protected under attorney-client privilege; however, lower courts had allowed for an in camera review (a private examination by a judge) based on suspicion that they contained evidence supporting a crime-fraud exception to this privilege. The Supreme Court held that such in camera reviews are permissible when there is reasonable cause to suspect lawyer-client communications have been made with intent to commit or cover up a crime or fraud - even if those suspicions arise from legal materials rather than independent evidence. However, it also clarified that mere allegations without substantiating evidence do not suffice for invoking this exception nor warranting such review.

In the dissenting opinion for Church of Scientology of California v. United States and Frank S. Zolin, Justice Stevens argued that the majority's decision to allow an in camera review by a district court judge was inappropriate because it violated attorney-client privilege. He believed that this privilege should be absolute and not subject to exceptions or qualifications, even when there are allegations of crime or fraud involved. Furthermore, he contended that such reviews could potentially lead to abuses of power by judges who might be biased against certain parties or influenced by their own personal beliefs or prejudices. Therefore, he concluded that the Court should have upheld the Ninth Circuit's ruling which denied the government's request for access to confidential communications between a lawyer and his client.