In the UPHAUS v. WYMAN case of 1960, the Supreme Court ruled in favor of Louis C. Wyman, Attorney General of New Hampshire. The dispute centered on whether Dr. Willard Uphaus could be held in contempt for refusing to disclose names associated with his World Fellowship organization during a state investigation into subversive activities under New Hampshire's Subversive Activities Act of 1951. The court had previously upheld that states have a right to protect themselves against potential threats to their security and can require individuals or organizations suspected of such threats to provide relevant information as part of an investigation process. In this context, it was deemed that Dr.Uphaus' refusal constituted obstruction and he was therefore found guilty by default due to non-compliance with legal requirements.

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. He contended that New Hampshire's Attorney General had no legitimate reason to demand a list of guests at World Fellowship, Inc., as it was not within his jurisdiction or relevant to any ongoing investigation into subversive activities in the state. Furthermore, he believed this action constituted an unwarranted invasion of privacy and could potentially deter individuals from attending such meetings due to fear of government reprisal or public backlash - thus infringing upon their constitutional rights. Justice Black also criticized the majority for failing to provide clear guidelines on when states can lawfully compel disclosure of private records, which he felt would lead to further abuses in future cases.