In the 1950 case Rogers v. United States, the Supreme Court ruled that a witness who answers some questions on a particular subject in front of a grand jury cannot refuse to answer further questions on the same subject by invoking their Fifth Amendment right against self-incrimination. The case involved William D. Rogers, an official with the Communist Party USA, who was called before a federal grand jury investigating communist activities in America. He answered several questions about his own involvement but refused to name other members of his party unit when asked, citing his Fifth Amendment rights as protection from potential self-incrimination. The court held that since he had already willingly provided some information about this topic without claiming privilege, he could not then selectively invoke it for subsequent related inquiries.

In the dissenting opinion for Rogers v. United States, Justice Robert H. Jackson disagreed with the majority's decision to uphold a contempt of court conviction against a grand jury witness who refused to answer questions after being granted immunity from prosecution. He argued that the Fifth Amendment right against self-incrimination should not be waived simply because immunity is granted, and that it was unfair to punish someone for refusing to testify out of fear of potential criminal charges. Furthermore, he contended that forcing witnesses into such dilemmas undermines their dignity and freedom as individuals under American law.