In the case of Brooks v. United States in 1924, the Supreme Court ruled on an issue related to self-incrimination and confessions during police interrogations. The defendant, Brooks, was convicted for murder based largely on a confession he made while in police custody without having been informed of his right to remain silent or have legal counsel present. He appealed his conviction arguing that this violated his Fifth Amendment rights against self-incrimination. However, the Supreme Court upheld his conviction stating that because there were no federal laws at that time requiring law enforcement officers to inform suspects of their rights before questioning them (a requirement later established by Miranda v. Arizona), Brook's confession was admissible as evidence despite being obtained under potentially coercive circumstances.

In the dissenting opinion for Brooks v. United States, Justice McReynolds argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. He believed that there was not enough substantial evidence to prove beyond a reasonable doubt that Brooks had committed mail fraud as charged. The only direct evidence against him were letters he wrote which could be interpreted in different ways and did not necessarily indicate fraudulent intent or actions. Furthermore, McReynolds pointed out inconsistencies in witness testimonies used by the prosecution, suggesting they were unreliable sources of information. Therefore, he felt it was unjust to convict someone based on such weak and ambiguous proof when their liberty is at stake.