Eccles v. State
In Eccles v. State, 179 Ariz. 226, 877 P.2d 799 (Ariz. 1994) the Arizona Supreme Court struck down probation conditions that forced the defendant to "choose between incriminating himself and losing his probationary status by remaining silent."
The court only allowed a condition that required the defendant to "truthfully answer all questions that could not incriminate him in future criminal proceedings." While the court did hold that the defendant could be forced to talk about offenses for which he had already been convicted, the defendant had to do so only to the extent he had lost the privilege to remain silent. Based on the United States Supreme Court's decision in Minnesota v. Murphy, the court held that the government could "compel answers to incriminating questions only if it offers the probationer use immunity." (Eccles, 877 P.2d at 802.)