In the case of Vitarelli v. Seaton, Secretary of the Interior, et al., 1958, Frank J. Vitarelli was dismissed from his position in the Department of Interior due to alleged associations with communist organizations. The Supreme Court ruled that although he had no formal right to his job under civil service laws or regulations and could be fired at any time for any reason by his superiors, procedural requirements established by departmental regulation still needed to be followed during dismissal proceedings. In this case, those procedures were not adhered to as they should have been; therefore, Vitarelli's dismissal was deemed unlawful and improper by the court because it violated administrative law principles requiring agencies to follow their own rules when taking action against individuals.

In the dissenting opinion for Vitarelli v. Seaton, Justice Clark argued that the majority's decision was based on a misinterpretation of Department of Interior regulations and an overreach into administrative matters. He contended that these regulations did not provide any substantive rights to employees but were merely procedural guidelines for internal use by management. Therefore, he believed they should not be used as grounds for judicial review or intervention in employment decisions made within the department. Furthermore, he pointed out that Vitarelli had been given ample opportunity to defend himself against allegations during his dismissal process and thus had not been denied due process rights as claimed by the majority opinion.