In the case Joines v. United States, 1957, the defendant was convicted for refusing to answer questions before a grand jury regarding possible violations of federal laws prohibiting narcotics and gambling activities. The Supreme Court upheld his conviction despite his claim that he had been denied due process because he was not advised of his right against self-incrimination prior to questioning by the grand jury. The court ruled that it is not necessary for a witness appearing before a grand jury to be warned about their constitutional rights unless they are in custody or deprived of their freedom in some significant way. This decision affirmed that while individuals have protection from self-incrimination under the Fifth Amendment, this does not extend to requiring warnings about these rights during appearances before a grand jury.

In the dissenting opinion for Joines v. United States, it was argued that the majority's decision to uphold the conviction of a man accused of selling narcotics without a written order form from his buyer violated his Fifth Amendment rights against self-incrimination. The dissenting justices believed that requiring such an order form would essentially force him to provide evidence against himself in any potential criminal proceedings, as possession of this document could be used as proof he had sold drugs illegally. They also disagreed with the majority's interpretation of relevant federal laws and regulations governing drug sales, arguing they did not clearly require sellers to obtain these forms or penalize them for failing to do so. Furthermore, they felt there were serious questions about whether these rules could constitutionally apply in cases like this one where no actual sale took place because police intercepted the drugs before delivery.