In the case of In re Murchison, the U.S. Supreme Court ruled in 1954 that a judge cannot act as both an accuser and adjudicator in a legal proceeding. The case arose when Judge Charles W. Murchison acted as a "one-man grand jury" under Michigan law, investigating potential criminal activity and then presiding over contempt proceedings against two individuals who refused to answer his questions during the investigation. Both were found guilty of contempt by Judge Murchison himself, which they appealed on grounds that it violated their constitutional right to due process. The Supreme Court agreed with them unanimously (9-0), stating that no man can be a judge in his own case or have any other kind of unfair advantage while acting as such; this principle is universally regarded as vital for fair trials and impartial tribunals under our Constitution's Due Process Clause. Therefore, having Judge Murchison serve both roles was inherently biased and unconstitutional because he had essentially prosecuted these men before judging them guilty.

In the dissenting opinion for In re Murchison et al., Justice Harold H. Burton argued that the majority's decision was based on a misinterpretation of Michigan law and an overemphasis on potential bias in one-judge grand juries. He contended that there was no evidence to suggest actual prejudice or partiality by Judge Waterman, who acted as both judge and "one-man" grand jury in this case. Furthermore, he pointed out that Michigan law explicitly allows judges to act as one-person grand juries when necessary, which is common practice across many states at the time. Therefore, he believed it was inappropriate for federal courts to interfere with state court procedures unless they clearly violated constitutional rights - something he did not believe occurred in this instance.