In Lynam v. Illinois, the U.S. Supreme Court ruled in favor of defendant Albert Lynam who was convicted for selling narcotics without a written order form from the buyer, which violated an Illinois state law. The case centered on whether or not this conviction violated his Fifth Amendment right against self-incrimination as he would have had to incriminate himself by obtaining and keeping record of such forms. The court held that compelling someone to keep records that could be used against them in future criminal prosecutions is unconstitutional because it violates their rights under the Fifth Amendment's protection against self-incicrimation. Therefore, they overturned Lynam's conviction.

In the dissenting opinion for Lynumn v. Illinois, Justice Clark argued that the majority had incorrectly applied the standard of "involuntary confession." He believed that there was no evidence to suggest that Ms. Lynumn's confession was coerced or involuntary, and thus should not have been excluded from her trial proceedings. According to him, she confessed voluntarily after being informed by a police officer about possible consequences if convicted - which is part of their duty. The fact she might have misunderstood these potential penalties does not make her statement involuntary as per his view. Furthermore, he pointed out inconsistencies in Ms. Lynumn's account of events leading up to her arrest and subsequent interrogation which cast doubt on the credibility of her claims regarding coercion.