In Uphaus v. Wyman, the Supreme Court examined whether a state could compel an individual to disclose the names of guests at a summer camp suspected of having Communist affiliations. The case involved Dr. Willard Uphaus, who ran World Fellowship Inc., a New Hampshire-based organization that operated such camps and was subpoenaed by the state's attorney general to provide guest lists from 1954-55 as part of an investigation into subversive activities under New Hampshire’s anti-subversion law. Uphaus refused on grounds it violated his First Amendment rights and was held in contempt. The Supreme Court upheld this decision with a 5-4 vote, ruling that states have significant interest in protecting themselves against potential threats to their government; thus outweighing any infringement upon freedom of association posed by revealing these names. This case is notable for its context during America's "Red Scare" era when fears over communist infiltration were high.

In the dissenting opinion for Uphaus v. Wyman, Justice Hugo Black argued that the majority's decision violated Dr. Uphaus' First Amendment rights to freedom of speech and association by compelling him to disclose membership lists from a summer camp he ran which was suspected of having Communist affiliations. He contended that this ruling would have a chilling effect on free expression, as it could deter individuals from joining or associating with organizations out of fear their identities might be revealed under state investigations. Furthermore, Justice Black criticized the New Hampshire Attorney General’s investigation into subversive activities as being too broad and lacking in specific charges against Dr. Uphaus or his organization; thus infringing upon constitutional protections against unreasonable searches and seizures (Fourth Amendment). In essence, he believed that without concrete evidence suggesting criminal activity or clear danger posed by an individual/group, such intrusive probes were unjustified.