In the case of St. Regis Paper Co. v. United States, 1961, the U.S Supreme Court ruled that a corporation could not refuse to produce business records on Fifth Amendment grounds. The St. Regis Paper Company was subpoenaed by a grand jury investigating possible antitrust violations and asked to provide certain documents related to its operations. The company refused, arguing that producing these documents would violate its Fifth Amendment right against self-incrimination. The court disagreed with this argument and held that corporations do not have the same level of constitutional protection as individuals under the Fifth Amendment because they are artificial entities created by state law for specific purposes such as conducting business or promoting charitable causes. Therefore, corporations cannot invoke personal privacy rights in order to avoid complying with lawful subpoenas or other types of legal requests for information about their activities. This decision clarified an important aspect of corporate law and has been cited in many subsequent cases involving similar issues.

In the dissenting opinion for St. Regis Paper Co. v. United States, Justice Harlan argued that the majority's decision to allow evidence obtained through an administrative subpoena was a violation of Fourth Amendment rights against unreasonable searches and seizures. He contended that this ruling effectively allowed government agencies to bypass obtaining a search warrant by using an administrative subpoena instead, which requires less stringent standards of proof than warrants do under criminal law procedures. This could potentially lead to abuse of power by these agencies in their investigations, as they can now easily access private records without sufficient justification or oversight from courts. Furthermore, he disagreed with the majority's view that corporations have lesser privacy rights compared to individuals; he believed that businesses should also be protected from unwarranted intrusions into their affairs by state authorities just like any other entity or person would be under constitutional law principles.