Brogan answered falsely when IRS and Department of Labor agents asked if he had received cash or gifts from a company whose employees were represented by the union in which he was an officer. Brogan was convicted on federal bribery charges and for making a false statement within the jurisdiction of a federal agency. He appealed, contending that false statements to federal investigators do not include mere denials, which are protected by the Fifth Amendment, because it holds that a person cannot be forced to testify against himself. Did Brogan have a right to use the Fifth Amendment in this situation? [Brogan v. United States, 118 S. Ct. 805, U.S. Supreme Court (1998)]