 In the same year as the railroad takings case , the Court evaluated what procedural trial rights implicated the " fundamental principles of liberty " expressed in Hurtado . In Hovey v. Elliot , the Supreme Court specifically applied the Due Process Clause to some fair trial guarantees , holding that due process " secures an ' inherent right of defense ' " . Despite that broad statement , the Court emphasized that due to procedural issues with the case itself " our opinion is therefore exclusively confined to the case before us . " 
