In the 1942 case Endicott Johnson Corp. et al. v. Perkins, Secretary of Labor, the U.S Supreme Court ruled that a federal agency has the power to subpoena company records as part of an investigation into potential violations of labor laws. The court held that such subpoenas are not unconstitutional and do not violate Fourth Amendment protections against unreasonable searches and seizures if they are specific in nature and relevant to an ongoing inquiry by a government agency with appropriate jurisdiction over the matter at hand. In this particular case, Frances Perkins, then-Secretary of Labor under President Franklin D Roosevelt's administration had issued a subpoena for certain records from shoe manufacturer Endicott Johnson Corporation during an investigation into alleged wage law violations.

In the dissenting opinion for Endicott Johnson Corp. et al. v. Perkins, Secretary of Labor, Justice Owen Roberts disagreed with the majority's interpretation of "necessary" in relation to a government contract clause that allowed the Secretary of Labor to cancel contracts if it was deemed necessary for national defense purposes. He argued that this power should only be exercised when there is an immediate and direct threat to national security or defense production, not merely because labor disputes might arise in future as feared by the majority justices. Furthermore, he contended that such broad interpretation could potentially lead to abuse of power by administrative officials who may use it arbitrarily without any real necessity or urgency related directly to national defense needs.