In the 1969 case Rowan v. United States Post Office Department, the Supreme Court ruled in favor of a statute that allowed homeowners to remove their names from mailing lists and refuse any further mailings from specific organizations. The appellants, who were businesses engaged in selling books through the mail, argued that this violated their First Amendment rights as it restricted their freedom of speech by limiting their ability to communicate with potential customers. However, the court held that an individual's right to privacy outweighed these concerns. They stated that if a recipient found content objectionable and wished not to receive such materials again they had every right under law to do so without government interference into what is or isn't objectionable material for each person individually.

In the dissenting opinion for Rowan v. United States Post Office Department, Justice Hugo Black argued that the majority's ruling violated First Amendment rights to free speech and press. He contended that allowing individuals to decide what mail they receive could lead to a chilling effect on these constitutional protections. In his view, if senders of controversial or unpopular material feared being blocked by recipients who disagreed with their views, it might discourage them from sending such materials altogether. This would effectively limit public discourse and undermine democratic principles. Furthermore, he questioned whether this law was truly necessary given existing laws against obscene materials and frauds through mails which already protected people from unwanted offensive content in their mailboxes.