Adamson v. California, 332 U.S. 46 (1947), was a United States Supreme Court case regarding the incorporation of the Fifth Amendment of the Bill of Rights.

[3] Justice Felix Frankfurter wrote a concurrence, arguing that incorporation of the Bill of Rights by the due process clause of the Fourteenth Amendment would "tear up by the roots much of the fabric of law in the several States, and would deprive the States of opportunity for reforms in legal process designed for extending the area of freedom.

[6] Justice Hugo Black, however, strongly opposed the decision and wrote a lengthy dissenting opinion, in which he argued for the incorporation of the first eight amendments of the Bill of Rights.

I believe that formula to be itself a violation of our Constitution, in that it subtly conveys to courts, at the expense of legislatures, ultimate power over public policies...."[8] Because of the belief that natural law actually restricted the rights of citizens under the Constitution, Black also called for the overruling of Twining v. New Jersey (1908) in which the Court turned to natural law to support its decision.

He stated, "Occasions may arise where a proceeding falls so far short of conforming to fundamental standards of procedure as to warrant constitutional condemnation in terms of a lack of due process despite the absence of a specific provision in the Bill of Rights.