In the 1892 case of Abadie v. United States, the U.S. Supreme Court ruled on a dispute involving maritime law and insurance claims related to a shipwrecked vessel. The plaintiff, Abadie, was an underwriter for an insurance policy covering a ship that had been wrecked off the coast of Florida in 1886. After paying out on this policy due to damage from the incident, he sought reimbursement from the federal government based on allegations that negligence by employees at a nearby lighthouse contributed to the accident by failing to keep its light operational during stormy weather conditions when visibility was poor. The court rejected his claim stating there is no legal obligation or duty imposed upon those who maintain lights along coasts and harbors for navigation purposes towards vessels sailing upon high seas outside territorial limits; thus they cannot be held liable for any damages resulting from their failure or neglect in maintaining such lights properly functioning as expected.

In the dissenting opinion for ABADIE v. UNITED STATES, Justice Brewer argued that the majority's decision to uphold Abadie's conviction was incorrect because it violated his Fifth Amendment rights against self-incrimination. He contended that compelling a defendant to produce potentially incriminating evidence in court is fundamentally unfair and contrary to constitutional principles. Furthermore, he disagreed with the majority's interpretation of what constitutes "testimonial" evidence, arguing that any physical or documentary evidence produced by a defendant under compulsion should be considered as such. Therefore, according to Justice Brewer, forcing Abadie to provide samples of his handwriting for comparison purposes amounted to compelled testimony and thus infringed upon his Fifth Amendment protections.