In the case of National Association for the Advancement of Colored People v. Alabama ex rel. Patterson, Attorney General (1957), the Supreme Court ruled in favor of NAACP, stating that Alabama's demand for NAACP to reveal its membership list violated constitutional rights to freedom of association and due process under the Fourteenth Amendment. The state had sought this information as part of a legal action questioning whether or not NAACP was conducting business within Alabama without proper qualification. However, citing potential threats and public hostility towards its members if their identities were disclosed, NAACP refused to comply with this order leading to a contempt fine by an Alabama court which was later overturned by U.S Supreme Court ruling.

In the case of NAACP v. Alabama, Justice Frankfurter dissented from the majority opinion. He argued that while he agreed with the Court's commitment to protecting freedom of association, he disagreed with its decision to intervene in a state court proceeding before it had been fully completed. He believed that this violated principles of federalism and judicial restraint by interfering prematurely in a matter that should have been left for resolution by state courts. Furthermore, Frankfurter expressed concern about potential abuse of such interventionist power by future Courts if not properly checked or limited.