In Doyle v. Ohio, the U.S. Supreme Court ruled that a defendant's silence after receiving Miranda warnings cannot be used against them in court to imply guilt. The case involved two men, Robert Doyle and Bruce Wood, who were arrested for selling marijuana and remained silent when they were read their rights under the Miranda warning by police officers. During their trial, prosecutors attempted to use this silence as evidence of guilt which led to both defendants being convicted. However, on appeal at the Supreme Court level it was decided that using a defendant’s post-Miranda silence as an implication of guilt violated their Fifth Amendment right against self-incrimination and Fourteenth Amendment right to due process.

In the dissenting opinion for Doyle v. Ohio, Justice Rehnquist disagreed with the majority's ruling that using a defendant's post-arrest silence as evidence of guilt violated their Fifth Amendment rights. He argued that Miranda warnings were not intended to protect defendants from all uses of their silence, but only from compelled self-incrimination in custodial interrogation settings. Therefore, he believed it was permissible for prosecutors to use a defendant’s post-Miranda warning silence against them at trial if they chose not to testify on their own behalf or offered an exculpatory story inconsistent with this silence. Furthermore, he contended that there is no inherent unfairness or constitutional violation in allowing jurors to consider whether such inconsistency indicates dishonesty or unreliability.