In the 1996 case, Regents of the University of California v. John Doe, a former employee sued the university for allegedly violating his constitutional rights by firing him due to his political beliefs and affiliations. The U.S. Supreme Court ruled in favor of the university, stating that it had qualified immunity from such lawsuits under federal law because its actions did not violate clearly established statutory or constitutional rights which a reasonable person would have known about at that time. This decision reinforced previous rulings establishing that public institutions and their employees are protected from liability for civil damages unless they knowingly violate an individual's legal rights.

The dissenting opinion in the case of Regents of the University of California v. John Doe argued that federal law does not preempt state tort claims for invasion of privacy based on disclosure of personal information. The dissent pointed out that Congress had specifically provided a remedy for such invasions, and thus it was clear that they intended to allow individuals to seek redress through state courts as well. They also noted that there was no conflict between federal and state laws in this area, so preemption should not apply. Furthermore, they contended that allowing states to provide additional remedies would further Congress's goal of protecting individual privacy rights rather than undermining it.