In the case of Kugler, Attorney General of New Jersey, et al. v. Helfant in 1974, the Supreme Court ruled on issues related to self-incrimination and immunity from prosecution. The respondent, a judge who was under investigation for corruption charges by a state grand jury refused to testify citing his Fifth Amendment right against self-incrimination unless he was granted full transactional immunity (immunity from future prosecution). The State offered use immunity (protection only from the use of that testimony in subsequent criminal proceedings), which he rejected. He then sought federal relief claiming that without full transactional immunity his constitutional rights were violated. The Supreme Court held that since there was no threat of federal prosecution stemming from compelled testimony before a state grand jury and because the scope of protection provided by use-immunity is coextensive with the scope protected by Fifth Amendment privilege itself; therefore it does not violate any constitutional rights if states offer only use-immunity instead of transactional one.

In the dissenting opinion for Kugler v. Helfant, Justice William O. Douglas argued that the majority's decision was a departure from established precedent regarding self-incrimination and immunity statutes. He contended that by allowing state officials to prosecute an individual who had previously been granted immunity in exchange for testimony, they were effectively punishing him twice for the same offense - once through his compelled testimony and again through prosecution based on evidence derived from it. This, he believed, violated both Fifth Amendment protections against double jeopardy and Fourteenth Amendment guarantees of due process. Furthermore, he disagreed with the majority's assertion that there was no constitutional violation because Helfant could have refused to testify; this argument ignored realities of power dynamics between individuals and government authorities.