In Whalen v. Roe, the U.S Supreme Court ruled on a case involving privacy rights and state power to maintain records of controlled substance prescriptions. The New York State Controlled Substance Act of 1972 required doctors to provide the state with information about patients receiving certain types of drugs, which was then stored in a centralized database. A group of patients and physicians sued Richard D. Whalen, Commissioner of Health for New York State at that time, arguing this violated their constitutional right to privacy by disclosing personal medical information without consent. The court held that while individuals have a constitutionally protected interest in avoiding disclosure of personal matters, it did not find any unconstitutional invasion into those interests by the act's requirements as there were sufficient security measures preventing public access or misuse. Furthermore, they noted that states have an interest in health matters including controlling drug abuse through record-keeping systems like these. However, Justice John Paul Stevens wrote separately emphasizing potential dangers if such databases are misused but concurred with majority since he found no evidence suggesting improper use or risk thereof under current procedures.

In the dissenting opinion for Whalen v. Roe, Justice Brennan argued that the New York State Controlled Substance Act of 1972 violated an individual's constitutional right to privacy. He believed that patients should have control over their personal information and medical records without interference from state authorities. The law required doctors to provide copies of prescriptions for certain drugs to a centralized computer system, which he saw as an unwarranted intrusion into private matters between doctor and patient. Furthermore, he expressed concern about potential misuse or abuse of this sensitive data by government officials or other unauthorized individuals who might gain access to it inappropriately. In his view, such risks outweighed any benefits derived from monitoring prescription drug use more closely in order to prevent illegal distribution or misuse.