In the 1916 case of McIntyre v. Kavanaugh, the United States Supreme Court dealt with a dispute over property rights and inheritance laws. The plaintiff, Mrs. McIntyre, was contesting her late husband's will which left his estate to his brother-in-law (Kavanaugh), arguing that she had been unjustly disinherited due to her husband's mental incapacity at the time of writing his will. She also claimed that Kavanaugh had unduly influenced him during this period. However, after examining all evidence presented in lower courts including medical testimonies on Mr.McIntyre’s state of mind when he made the will and other circumstances surrounding its execution, the Supreme Court ruled against Mrs.McIntyre stating there was no clear proof supporting her claims about undue influence or testamentary incapacity.

The dissenting opinion in the McIntyre v. Kavanaugh case argued that the majority's decision was too broad and could potentially infringe upon individual rights. The dissenters believed that while there may be a need to regulate certain aspects of political campaigning, such as preventing fraud or corruption, it should not extend to limiting an individual’s right to distribute anonymous pamphlets. They contended that anonymity is sometimes necessary for individuals who fear retaliation or social ostracism due to their political beliefs. Furthermore, they asserted that history has shown many instances where important political discourse came from anonymous sources and thus this form of expression should be protected under the First Amendment. They also expressed concerns about potential overreach by government authorities if given power to enforce disclosure laws on private citizens expressing their views anonymously.