In the 1932 case of Clark v. United States, the Supreme Court ruled on a matter related to self-incrimination and perjury. The defendant, Clark, was charged with perjury after she testified in her own defense during a previous trial for conspiracy to violate prohibition laws and was subsequently convicted. She appealed this conviction arguing that it violated her Fifth Amendment right against self-incrimination as her testimony from the first trial had been used against her in the second one. However, the Supreme Court upheld Clark's conviction stating that while defendants cannot be compelled to testify against themselves under oath, if they choose to do so voluntarily their statements can be used against them later if found false or misleading. Therefore, there is no constitutional immunity from prosecution for perjury committed while testifying willingly.

In the dissenting opinion for Clark v. United States, Justice McReynolds expressed his disagreement with the majority's decision to uphold Clark's conviction. He argued that there was not enough evidence presented at trial to prove beyond a reasonable doubt that Clark had committed perjury when he denied receiving money from an individual named Sullivan. According to Justice McReynolds, the only evidence against Clark was testimony from two witnesses who were both unreliable and untrustworthy due to their criminal backgrounds and potential motives for lying on the stand. Furthermore, he pointed out inconsistencies in their testimonies which further undermined their credibility. Therefore, Justice McReynolds believed it was unjustifiable and unfair to convict someone based solely on such questionable evidence without any corroborating proof or confirmation of guilt.