In the 1961 case of Public Affairs Associates, Inc. v. Rickover, the U.S. Supreme Court ruled in favor of Admiral Hyman G. Rickover, who was sued by a publishing company for copyright infringement after he included an unattributed quote from one of their books in his speech to Congress and subsequent publication without permission or payment. The court held that since Rickover's use of the material was not commercial but rather for public information purposes as part of his official duties as a government officer, it did not constitute copyright infringement under fair use doctrine principles which allow limited use of copyrighted material without requiring permission from rights holders.

In the dissenting opinion for Public Affairs Associates, Inc. v. Rickover, Justice Hugo Black disagreed with the majority's decision that Admiral Hyman G. Rickover could not be sued for copyright infringement because he was acting within his official duties when he delivered a speech that was later published without permission by Public Affairs Press. Justice Black argued that this ruling expanded governmental immunity too far and threatened to undermine copyright protections guaranteed by Congress under Article I of the Constitution. He contended that if government officials were allowed to infringe copyrights without fear of legal repercussions simply because they were performing their official duties, it would discourage authors from creating new works and thus hinder progress in science and useful arts - which is precisely what copyright laws are designed to promote.