In the 1913 case of Wilson v. United States, Charles Willard Wilson was convicted for perjury in a federal court and appealed to the Supreme Court on grounds that he had been compelled to testify against himself, violating his Fifth Amendment rights. The issue at hand was whether or not an individual could be prosecuted for perjury if they lied under oath after being granted immunity from prosecution. The Supreme Court ruled against Wilson, stating that while the Fifth Amendment protects individuals from being forced to provide self-incriminating testimony, it does not protect them when they choose to lie under oath instead of claiming their right against self-incrimination. Therefore, even though Wilson had been given immunity from prosecution regarding certain offenses about which he testified before a grand jury, this did not extend protection towards committing perjury during his testimony.

In the dissenting opinion for Wilson v. United States, Justice Hughes argued that the defendant's constitutional rights were violated when he was forced to produce self-incriminating evidence in court. He disagreed with the majority's interpretation of the Fifth Amendment and believed it protected individuals from being compelled to provide any form of testimonial evidence against themselves, not just verbal testimony. In his view, forcing a person to surrender physical objects or documents as evidence still constituted compulsion and could potentially lead to self-incrimination. Therefore, he contended that requiring Wilson to present his private papers in court infringed upon his right against self-incrimination under the Constitution.