In the 1987 case of Doe v. United States, a former Central Intelligence Agency (CIA) agent sought to publish a memoir detailing his experiences in the agency. The CIA objected on grounds that it contained classified information and could harm national security interests. The Supreme Court ruled in favor of the U.S government, stating that an agreement signed by Doe upon employment with the CIA prevented him from publishing any material without prior approval from the agency. This ruling upheld restrictions on free speech for national security reasons when there is a pre-existing non-disclosure agreement involved.

In the dissenting opinion for DOE v. UNITED STATES, 1987, it was argued that the majority's decision to allow a government agency to withhold information from an individual about their own employment history violated principles of privacy and fairness. The dissenting justices believed that this ruling gave too much power to government agencies at the expense of individuals' rights. They contended that such unchecked authority could lead to abuses by those in power and undermine public trust in governmental institutions. Furthermore, they expressed concern over how this might set a dangerous precedent for future cases involving similar issues of personal privacy versus state interests.