In the case of National Labor Relations Board v. Robbins Tire & Rubber Co., the Supreme Court was tasked with determining whether a company could be compelled to disclose witness statements prior to an unfair labor practice hearing under Section 11(2) of the National Labor Relations Act (NLRA). The court held that such pre-hearing disclosure was not required by NLRA, nor did it fall within "the confines of 'full and adequate enforcement'". The court reasoned that requiring companies to reveal their evidence before hearings would discourage witnesses from providing statements due to fear of retaliation, thus undermining effective enforcement. Furthermore, they noted that there were other ways for parties involved in these cases to prepare for hearings without needing access to this information beforehand. This decision upheld employers' rights while also considering potential negative impacts on employees who might come forward as witnesses in labor disputes.

In the dissenting opinion for the National Labor Relations Board v. Robbins Tire & Rubber Co., Justice William Rehnquist argued that the majority's decision to allow pre-hearing disclosure of witness statements collected by NLRB investigators was a misinterpretation of Section 7(c) of the Administrative Procedure Act (APA). He contended that this section should be interpreted as providing an exemption from disclosure for investigatory files compiled in anticipation of litigation, including witness statements. Furthermore, he disagreed with the majority’s view that such disclosures would not hinder future investigations or harm witnesses. Instead, he believed it could discourage cooperation from potential witnesses who may fear retaliation if their statements are disclosed prematurely. Additionally, Justice Rehnquist criticized how broadly and loosely defined "party" is under APA's provisions which might lead to unnecessary complications and confusion in its application.