In the case of Meese v. Keene in 1986, California State Senator Brian Keene challenged the U.S. Department of Justice's classification of three Canadian films as "political propaganda" under the Foreign Agents Registration Act (FARA). The Supreme Court ruled in favor of Attorney General Edwin Meese, upholding that FARA did not violate First Amendment rights and its use to label foreign political material was constitutional. The court reasoned that labeling these films as such does not restrict their distribution but merely provides information for viewers to consider when evaluating content. Furthermore, it clarified that 'propaganda' in this context doesn't carry a negative connotation; instead, it refers broadly to any systematic propagation of particular ideas or doctrines by an identified sponsor.

In the dissenting opinion for Meese v. Keene, Justice Brennan disagreed with the majority's interpretation of "political propaganda" in the Foreign Agents Registration Act (FARA). He argued that this term was inherently pejorative and prejudicial, thus violating First Amendment rights by discouraging viewership based on government labeling rather than content. Brennan contended that FARA did not merely require disclosure but imposed a value judgment which could deter individuals from accessing such materials due to fear of social stigma or governmental reprisal. This, he believed, constituted an unwarranted intrusion into personal autonomy and freedom of thought protected under the Constitution. Furthermore, he criticized the Court’s reliance on dictionary definitions to interpret “propaganda,” arguing it ignored common usage and understanding where propaganda is often associated with manipulation and deceit.