In Haynes v. United States (1967), the U.S. Supreme Court ruled that a provision of the National Firearms Act violated an individual's Fifth Amendment rights against self-incrimination. The case involved a man named Miles Edward Haynes who was charged with unlawful possession of an unregistered firearm, which he argued would force him to admit to illegal activity and thus violate his constitutional rights if he were to comply with registration requirements under the law. In its decision, the court agreed with Haynes' argument and held that compelling individuals to register firearms constituted self-incrimination for those possessing them illegally, thereby violating their Fifth Amendment protections.

In the dissenting opinion for Haynes v. United States, Justice Harlan disagreed with the majority's interpretation of the Fifth Amendment in relation to self-incrimination. He argued that a person should not be able to use their potential criminal liability as an excuse to avoid complying with regulatory statutes such as firearm registration laws. In his view, this would undermine law enforcement efforts and could potentially allow criminals to evade justice by refusing compliance on constitutional grounds. Furthermore, he contended that if Congress intended for these regulations not to apply in cases where they might incriminate someone, it would have included explicit provisions within the legislation itself rather than relying on judicial interpretations of constitutional protections against self-incrimination.