In the 1998 case of National Aeronautics and Space Administration (NASA) v. Federal Labor Relations Authority, NASA challenged a decision by the Federal Labor Relations Authority (FLRA) that required them to disclose certain information about their employees to labor unions. The FLRA had ruled that under section 7114(b)(4) of the Federal Service Labor-Management Relations Statute, NASA was obligated to provide names and home addresses of all its bargaining unit employees upon request from labor organizations. However, NASA argued this violated privacy rights protected by Freedom of Information Act exemptions. The Supreme Court sided with FLRA in an unanimous decision stating that disclosure did not violate any law or substantial privacy interest as it served a public interest in collective bargaining. It held that federal agencies must disclose names and home addresses of all their bargaining unit employees to unions representing those workers if requested for purposes related with collective bargaining unless there are countervailing interests against disclosure.

In the dissenting opinion for the case of National Aeronautics and Space Administration (NASA) v. Federal Labor Relations Authority, Justice Scalia argued that NASA should not be required to bargain with a union over drug testing policies because it is an issue related to "internal security practices," which are exempt from collective bargaining under federal law. He disagreed with the majority's interpretation of this exemption, arguing that it should cover any practice designed to safeguard an agency's operations or assets against internal threats - including employee drug use. Furthermore, he contended that requiring agencies like NASA to negotiate such matters would undermine their ability to ensure safety and efficiency in their operations. Thus, while acknowledging unions' important role in protecting employees' rights, he believed this particular matter fell outside their purview.