an improvised content consisting of some but not all of the provisions of the first eight Amendments, selected on an undefined basis, with improvisation of content for the provisions so selected." This assertion would not carry the day, however. It was later rebuffed by a whole line of cases that incorporated many of the provisions of the first eight amendments of the Bill of Rights. Black's dissent 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. Specifically, Black argued that while the Court should not incorporate rights not specifically enumerated in the Bill of Rights, it should "extend to all the people of the nation the protection of [the specific enumerated rights of] the Bill of Rights." Black's dissent, beyond advocating for incorporation, was also a criticism of the Court's use of natural law in the arena of incorporation. Black thought that the Court's use of natural law to discard the argument that the right to be free from self-incrimination should be incorporated was misguided: "I further contend that the 'natural law' formula which the Court uses to reach its conclusion in this case should be abandoned as an incongruous excrescence on our Constitution. 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...." 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. Indeed, Black thought that the Court's guiding light for incorporation, asking whether the interest at stake is "implicit in the concept of ordered liberty," "degraded the constitutional safeguards of the Bill of Rights, and simultaneously appropriate for this Court a broad power which [it is] not authorized by the Constitution to exercise." Murphy's dissent Justice Frank Murphy agreed, in sum and substance, with Black but would have also left open the option that the Court incorporate rights not specifically enumerated in the Bill of Rights. 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