Does a state have a constitutional obligation to compel a witness to testify before a grand jury?

Thus, as we noted above, where a state "compels testimony by threatening to inflict potent sanctions unless the constitutional privilege is surrendered, that testimony is obtained in violation of the Fifth Amendment." Lefkowitz v. Cunningham, 431 U.S. at 805, 97 S.Ct. at 2135 (statute requiring forfeiture of political party office for failure to testify before grand jury invalid). ¹⁴ "The test is whether, considering the totality of the circumstances, the free will of the witness was overborne." Washington, 431 U.S. at 188, 97 S.Ct. at 1819; see also Camp, 72 F.3d at 761 (accord).