In the case of Harrison, Attorney General of Virginia, et al. v. National Association for the Advancement of Colored People (NAACP) et al., 1958, the Supreme Court ruled in favor of NAACP and against a Virginia law that required organizations to disclose their membership lists. The state argued that this was necessary to regulate solicitation practices and prevent fraud; however, NAACP claimed it violated its members' First Amendment rights by potentially exposing them to harassment or retaliation due to their association with an organization advocating racial equality during a time when such views were controversial. The court agreed with NAACP's argument stating that compulsory disclosure could infringe upon freedom of assembly as protected by the First Amendment since fear of reprisal might deter individuals from joining or remaining part of groups whose beliefs are unpopular.

In the dissenting opinion for Harrison v. NAACP, Justice Frankfurter argued that the court should have abstained from deciding on this case until Virginia courts had a chance to interpret their own laws. He believed that it was not clear whether or how these state statutes would be applied and therefore, any decision by the Supreme Court would be premature. Furthermore, he emphasized that federal courts should avoid interfering with state legal processes unless absolutely necessary in order to maintain respect for states' rights within our federal system of government. In his view, rushing into judgment could undermine this delicate balance and potentially lead to unnecessary conflicts between different levels of government.