In the case of National Association for the Advancement of Colored People (NAACP) et al. v. Williams, Revenue Commissioner, 1958, the Supreme Court ruled in favor of NAACP and against Alabama's attempt to obtain membership lists from the organization as part of a tax investigation. The court held that such an action violated members' rights to freedom of association under the First Amendment because it could expose them to significant risks including economic reprisal, loss of employment and threat to their physical wellbeing due to prevalent racial tensions at that time. This ruling was instrumental in protecting civil rights organizations during a period when they were often targeted by state governments seeking ways to undermine their efforts.

In the dissenting opinion for NAACP v. Williams, Justice Frankfurter argued that the Alabama statute requiring disclosure of NAACP's membership lists was constitutional and did not infringe upon First Amendment rights. He reasoned that states have a legitimate interest in regulating corporations within their jurisdiction, including ensuring they comply with state laws and regulations. In his view, this includes having access to information about an organization’s members if it is relevant to enforcing those laws or regulations. Furthermore, he contended that any potential harm from disclosing membership lists would be speculative at best because there were no concrete examples of retaliation against NAACP members due solely to their association with the group.