Reaffirming that the Fifth Amendment privilege against self-incrimination was not applicable to the states, the Supreme Court reiterated that the due process clause of the Fourteenth Amendment incorporated only those procedural rights considered essential to a fair trial.
When tried for murder, Admiral D. Adamson did not testify, because of his prior criminal record. The district attorney, as permitted by applicable state law at the time, told the jury that Adamson’s refusal to testify was a good reason to infer his guilt. The Supreme Court had earlier permitted this practice in Twining v. New Jersey
Justice Wiley B. Rutledge, Jr., along with Justice Frank Murphy, departed from Hugo Black's dissent in Adamson in contending that the Court should not restrict the meaning of due process to the rights contained in the first eight amendments.
Adamson is notable primarily because of Hugo L. Black’s
Barron v. Baltimore
Griffin v. California
Malloy v. Hogan
Palko v. Connecticut
Twining v. New Jersey