In the case of Louise Renne, San Francisco City Attorney, et al. v. Bob Geary, et al., 1990, the U.S Supreme Court dealt with a dispute over an amendment to the city charter in San Francisco that required non-civil service employees of the Public Defender's Office to be dismissed and replaced by civil service employees. The plaintiffs argued that this violated their right to political association under the First Amendment as they were being fired for not belonging to a certain political group (civil servants). However, the court ruled against them stating that employment decisions based on party affiliation are only unconstitutional when it affects public confidence in governmental integrity or inhibits independent judgment on part of government workers. Since neither was applicable here because these positions did not involve policy-making or confidential information access where political loyalty could be crucially important; hence no violation occurred.

In the dissenting opinion for Louise Renne, San Francisco City Attorney, et al. v. Bob Geary, et al., Justice Marshall argued that the majority's decision to uphold a city charter amendment prohibiting former police officers from serving on the Police Commission was misguided and violated principles of equal protection under law. He contended that there was no rational basis for excluding all former police officers from serving on this commission as it would not necessarily lead to bias in favor of current officers or against citizens' complaints about police conduct. Furthermore, he pointed out that other cities allowed ex-officers to serve without any apparent harm to their ability to oversee local law enforcement effectively and fairly. Thus, he believed such blanket exclusion based solely on prior employment status constituted an arbitrary discrimination violating constitutional rights.