In the case of In re Swan, Petitioner (1893), the U.S. Supreme Court dealt with a dispute over whether an individual could be held in contempt for refusing to answer questions before a grand jury after being granted immunity from prosecution. The petitioner, Swan, was subpoenaed by a federal grand jury investigating potential violations of antitrust laws but refused to testify on the grounds that his answers might incriminate him. He was then offered immunity from prosecution under federal law and still declined to answer questions, leading to him being held in contempt of court. The Supreme Court upheld this decision and ruled that when someone is given full immunity from prosecution under federal law they cannot refuse to testify based on their Fifth Amendment right against self-incrimination. This ruling clarified how far-reaching protections against self-incrimination are within American jurisprudence and established precedent regarding testimonial compulsion when statutory immunities have been provided.

The dissenting opinion in the case of In re Swan, Petitioner, 1893 argued that the petitioner should not be held accountable for contempt charges. The justice believed that there was no clear evidence showing a willful disobedience to court orders by Mr. Swan and therefore he should not be punished for such an act. They also pointed out flaws in how the trial was conducted, suggesting it did not meet standards of fairness and due process required under law. Furthermore, they disagreed with the majority's interpretation of bankruptcy laws as applied to this case; arguing instead that these laws were designed to protect debtors from undue punishment or hardship rather than serve as tools for creditors seeking repayment.