In the case of Gibson v. Florida Legislative Investigation Committee, 1962, the U.S. Supreme Court ruled in favor of a local chapter leader of the National Association for Advancement of Colored People (NAACP), Reverend Theodore R. Gibson. The Florida Legislative Investigation Committee had subpoenaed Rev. Gibson to provide records and membership lists from his NAACP chapter as part of an investigation into Communist infiltration within organizations that advocated racial equality or civil rights reforms. Refusing to comply with this demand on grounds that it violated members' First Amendment rights, he was held in contempt by a state court and sentenced to jail time. The Supreme Court overturned this decision stating that compelling disclosure infringed upon freedom of association protected under the First Amendment unless there is a substantial relation between information sought and compelling state interest which wasn't demonstrated here by Florida's committee sufficiently enough to justify intrusion into NAACP’s internal affairs.

In the dissenting opinion for Gibson v. Florida Legislative Investigation Committee, Justice Harlan argued that the majority's decision to protect NAACP members from revealing their affiliations was misguided. He believed that states have a legitimate interest in investigating potential subversive activities and this should not be hindered by an overly broad interpretation of First Amendment rights. While acknowledging the importance of freedom of association, he contended it should not serve as a shield against reasonable state inquiries into potential threats to public safety or order. Furthermore, he disagreed with the majority's assertion that there was insufficient evidence linking racial agitation with communist activity; instead arguing such connections were plausible given historical context and thus warranted investigation by state authorities.