In the case Watkins v. Conway, 1966, the U.S Supreme Court ruled in favor of petitioner Lloyd Barenblatt who was convicted for contempt of Congress after refusing to answer questions about his alleged Communist affiliations during a hearing before the House Un-American Activities Committee (HUAC). The court held that HUAC had exceeded its authority by asking questions unrelated to its legislative purpose and violated Barenblatt's First Amendment rights. This decision significantly limited Congressional investigatory powers and marked an important shift in how such investigations were conducted thereafter.

In the Watkins v. Conway case, the dissenting opinion argued that the majority's decision was an overreach of judicial power and a misinterpretation of constitutional rights. The dissenters believed that Congress had acted within its powers to investigate matters related to national security and potential subversive activities. They contended that Watkins' refusal to answer questions about his past associations constituted non-compliance with a legitimate congressional inquiry, not an exercise of First Amendment rights as claimed by the majority. Furthermore, they asserted that it is not for courts but for Congress itself to determine what information is pertinent in such investigations. By ruling otherwise, they felt the Court was infringing upon legislative prerogatives and disrupting checks-and-balances system established by Constitution.