In Adamson v. California, 332 U.S. 46 (1947), the U.S. Supreme Court upheld a murder conviction despite claims by the defendant that the prosecutor's comments about his refusal to testify at trial violated his due process rights. The defendant, Admiral Dewey Adamson, was accused of breaking into the Los Angeles home of a sixty-four-year-old widow and subsequently murdering her. During the trial, Adamson refused to testify in his own defense, and the prosecutor suggested that the jury could take the defendant's silence as evidence of guilt. The underlying issue in the case was the degree to which the right against self-incrimination provided in the Fifth Amendment was to be applied, if at all, to the states via the Due Process Clause of the Fourteenth Amendment under the doctrine of incorporation.