Identifying Non-Fundamental Rights in Selective Incorporation

In the landmark case of Palko v. Connecticut (1937), the Supreme Court ruled that certain rights are fundamental to the concept of 'ordered liberty' and therefore applicable to the states through the Fourteenth Amendment. This case significantly shaped the understanding of selective incorporation.

Based on this precedent, which of the following rights was not recognized by the Supreme Court as fundamental in the Palko decision, and thus took longer to apply to the states?