In the case of John Doe Agency and John Doe Government Agency v. John Doe Corporation in 1989, the U.S Supreme Court addressed issues related to the Freedom of Information Act (FOIA). The central question was whether documents compiled for law enforcement purposes could be exempted from disclosure under FOIA even if a violation of law did not occur. The court ruled that such records could indeed be withheld, regardless of whether an actual legal violation took place or not. This decision expanded the interpretation of Exemption 7(A) within FOIA, which allows agencies to withhold "records or information compiled for law enforcement purposes" if their release could interfere with ongoing investigations. It clarified that this exemption applies broadly to any federal agency's investigatory files and is not limited only to those cases where illegal activities were found.

In the dissenting opinion for JOHN DOE AGENCY AND JOHN DOE GOVERNMENT AGENCY v. JOHN DOE CORPORATION, Justice Scalia disagreed with the majority's interpretation of Exemption 7(C) in the Freedom of Information Act (FOIA). He argued that this exemption should protect any information compiled for law enforcement purposes if its release could reasonably constitute an unwarranted invasion of personal privacy. The majority's decision to narrow down this protection only to situations where there is a significant public interest in disclosure was seen by Scalia as inconsistent with FOIA’s language and purpose. Furthermore, he contended that such narrowing would lead to unnecessary litigation over what constitutes "significant" public interest. In his view, Congress intended a broader protection under Exemption 7(C), which does not require balancing private against public interests on a case-by-case basis.