In the case of United States v. Webster L. Hubbell, the U.S Supreme Court ruled in favor of Hubbell by a 8-1 majority in 1999. The court held that the Fifth Amendment privilege against self-incrimination protects a defendant from being compelled to disclose incriminating information, even if it is only used as a lead to other evidence. This decision came after former Associate Attorney General Webster L. Hubbell was indicted on charges stemming from documents he provided under an immunity agreement during independent counsel Kenneth Starr's Whitewater investigation into President Bill Clinton and his associates' real estate dealings in Arkansas. The government argued that while they couldn't use these documents directly due to their immunized status, they could use them as leads for further investigations which led to new charges against him unrelated to Whitewater inquiry itself - tax evasion and mail fraud related with his legal work post-government service. The Supreme Court disagreed with this argument stating that any derivative use of such materials violated Fifth Amendment rights unless prosecutors can prove their investigation didn't stem from those immunized testimonies or document productions.

In the dissenting opinion for United States v. Hubbell, Justice Thomas, joined by Justice Scalia, disagreed with the majority's interpretation of the Fifth Amendment's self-incrimination clause. They argued that producing documents under a subpoena does not involve testimonial communication because it doesn't require using "the contents of one's own mind" to explicitly or implicitly communicate some statement of fact. The act of producing documents is more akin to providing physical evidence like a blood sample than making a testimonial statement. Therefore, they contended that immunity should not extend to cover any incriminating information contained in those produced documents themselves as this would be an overly broad application of Fifth Amendment protections against self-incrimination.