In the case of Church of Scientology of California v. Internal Revenue Service, 1987, the Supreme Court ruled in favor of the IRS. The Church had sought tax-exempt status as a religious organization but was denied by the IRS due to its commercial activities and because it provided substantial private benefits to L. Ron Hubbard (its founder) and his family. The church sued for access to documents related to this decision under the Freedom of Information Act (FOIA). However, FOIA exempts from disclosure records or information compiled for law enforcement purposes that could interfere with enforcement proceedings if released prematurely. The court held that these exemptions applied even when an investigation did not result in an enforcement proceeding; thus, protecting such records from mandatory disclosure under FOIA requests made while investigations are ongoing or after they have been closed without resulting in an enforcement proceeding.

In the dissenting opinion for Church of Scientology of California v. Internal Revenue Service, Justice Brennan argued that the majority's decision was a misinterpretation of the Freedom of Information Act (FOIA). He contended that FOIA exemptions should be narrowly construed and any doubts about their applicability resolved in favor of disclosure. In his view, Exemption 7(C) did not apply to routine administrative information like mailing lists used by federal agencies. The majority’s broad interpretation could potentially shield vast amounts of governmental activity from public scrutiny which would undermine FOIA's purpose: promoting transparency and accountability in government operations. Furthermore, he disagreed with the majority’s assertion that privacy interests outweighed public interest in this case as it involved an organization rather than an individual taxpayer.