The case of Press-Enterprise Co. v. Superior Court of California, Riverside County in 1983 revolved around the issue of public access to preliminary hearings in criminal cases and whether closing such proceedings violated the First Amendment's guarantee of freedom of press. The Supreme Court ruled that these hearings should generally be open to the public and media unless there is a substantial reason for closure, which must be supported by specific findings on record showing an overriding interest likely to be prejudiced if not closed. In this particular case, it was found that no such compelling reasons were present; therefore, barring reporters from attending infringed upon their constitutional rights under the First Amendment.

In the dissenting opinion for Press-Enterprise Co. v. Superior Court of California, Riverside County, Justice John Paul Stevens argued that the majority's decision to require public access to preliminary hearings in criminal cases was a misinterpretation of the First Amendment and an overreach into state court procedures. He contended that while openness is important in judicial proceedings, it should not be absolute or mandated by federal law as states have their own rules regarding courtroom transparency which can vary based on local needs and circumstances. Furthermore, he expressed concern about potential negative impacts on defendants' rights due to increased media scrutiny during early stages of legal proceedings before all evidence has been presented or evaluated.