The Fuller Court unanimously ruled 9–0 in Counselman v. Hitchcock (1892) that Charles Counselman was entitled to invoke the protections of the Fifth Amendment when he was a grand jury witness. The government contended that Counselman was not entitled to invoke the Fifth Amendment because he was called as a witness, not as the focus of the criminal inquiry. However, the Court disagreed, emphasizing that it applied when a person was a “witness in any investigation.”