In the case of Minnesota v. Murphy, 1983, the U.S. Supreme Court ruled that a probationer's Fifth Amendment rights against self-incrimination were not violated when he was compelled to admit a crime to his probation officer during routine questioning. The defendant, Michael Patrick Murphy had been on probation for a false imprisonment conviction and admitted to his probation officer that he committed an unrelated rape-murder years prior without being warned about potential incrimination or having counsel present. This admission led to charges for which he was convicted and sentenced in state court but appealed claiming violation of his Fifth Amendment rights. However, the Supreme Court held that unless there is compelling evidence by authorities or if testimony is required under threat of penalty, then it does not violate one’s constitutional right against self-incrimination as these protections are primarily meant for courtroom settings rather than informal conversations with parole officers.

In the dissenting opinion for Minnesota v. Murphy, Justice Marshall argued that compelling a probationer to appear and answer questions without being warned about self-incrimination rights violated the Fifth Amendment. He believed that this case was not about whether a state can require a probationer to attend meetings with his probation officer but rather if it could compel him to incriminate himself at those meetings without immunity or warning of his constitutional privilege against self-incrimination. The majority's decision, according to Marshall, ignored established precedent regarding custodial interrogation and created an unjustifiable distinction between suspects in custody and individuals on parole or probation who are also under significant state control. Furthermore, he disagreed with the majority’s view that Murphy had waived his right by answering questions because he did so out of fear of losing his conditional liberty as a result of non-compliance.