Hopt v. Utah was a United States Supreme Court case that addressed the issue of whether a state could impose criminal penalties for the refusal to answer questions posed by a grand jury. The case arose when a grand jury in Utah issued a subpoena to a witness, who refused to answer certain questions on the grounds that they were irrelevant to the investigation. The witness was then charged with contempt of court and sentenced to jail. The Supreme Court held that the witness could not be punished for refusing to answer the questions. The Court reasoned that the Fifth Amendment of the United States Constitution protects individuals from being compelled to give testimony that could incriminate them. The Court further held that the state could not impose criminal penalties for the refusal to answer questions posed by a grand jury. The Court's decision in Hopt v. Utah established an important precedent in criminal law. It established that individuals cannot be punished for refusing to answer questions posed by a grand jury, as long as the questions could potentially incriminate them. This decision has been cited in numerous subsequent cases, and it remains an important part of criminal law today.

Justice Field, in his dissenting opinion for Hopt v. Utah, argued that the Fourteenth Amendment of the United States Constitution did not grant Congress the power to regulate criminal proceedings within a state. He believed that this was an issue which should be left up to each individual state and their respective laws. Justice Field further argued that if Congress had such authority then it would have been explicitly stated in the amendment itself or other federal legislation passed by Congress at some point since its adoption in 1868. He also noted that while there were certain aspects of criminal law where states could be regulated by federal law, those areas were limited and did not include matters related to trial procedures as seen with this case before them. In conclusion, Justice Field maintained his belief that any regulation regarding trial procedure fell under the jurisdiction of each individual state rather than being subject to congressional control through use of implied powers granted by amendments like the Fourteenth Amendment.