In Achilli v. United States, the Supreme Court ruled on a case involving an individual who was charged with tax evasion. The defendant, Achilli, argued that he had been improperly convicted because his Fifth Amendment rights were violated when he was compelled to provide incriminating evidence against himself during a previous civil audit by the Internal Revenue Service (IRS). He claimed this information was then used in his criminal trial for tax evasion. However, the Supreme Court disagreed and upheld his conviction. The court held that there is no constitutional right to be free from self-incrimination in non-criminal proceedings such as audits or investigations conducted by administrative agencies like IRS unless one specifically claims it at the time of questioning.

In the dissenting opinion for Achilli v. United States, Justice Brennan disagreed with the majority's interpretation of Section 346(a) of the Immigration and Nationality Act. He argued that this section should not be used to deny a defendant their Fifth Amendment rights against self-incrimination during deportation proceedings. According to him, Congress intended for these protections to apply in all judicial proceedings, including those related to immigration. Furthermore, he contended that using evidence from such proceedings in criminal trials violates a person’s constitutional rights because it compels them to testify against themselves under threat of deportation or imprisonment. This view was shared by Justices Black and Douglas who also dissented from the majority decision.