In the 1981 case United States Department of State v. Washington Post Co., the Supreme Court ruled in favor of The Washington Post, affirming that a section of the Freedom of Information Act (FOIA) did not exempt from disclosure records on foreign nationals maintained by U.S. government agencies abroad. The court held that Section 552(b)(3) only exempts matters specifically exempted from disclosure by another statute if such statute leaves no discretion to withhold or refers to particular types of matters withheld, and it does not refer to statutes which limit disclosure but do not prohibit it entirely. This decision upheld an earlier ruling by a lower court ordering the release of information requested by The Washington Post about Howard Hughes' right-hand man Robert Maheu's activities in Iran during late 1970s.

In the dissenting opinion for the case between United States Department of State and Washington Post Co., it was argued that the Freedom of Information Act (FOIA) should be interpreted broadly to promote transparency, not narrowly as a means to withhold information. The dissent disagreed with the majority's interpretation of FOIA Exemption 6, which protects personal privacy. They contended that this exemption should only apply when disclosure would constitute a clearly unwarranted invasion of personal privacy. In this case, where passport records were requested by a newspaper company for investigative journalism purposes, they believed there was significant public interest in disclosing such information about individuals who may have violated federal law or engaged in corruption abroad. Therefore, they felt that withholding these records did not serve any legitimate privacy interests but rather hindered important journalistic endeavors aimed at holding powerful individuals accountable.