This Triple Homicide Case Laid the Groundwork for the Right to Remain Silent

Look back at the 1919 murder trial that set the precedent for the 'Miranda' decision decades later.

miranda rights
Court scene: Trial Ziang Sung Wan (Library of Congress)

The U.S. legal requirement that anyone arrested must be informed that they may remain silent and that they have the right to an attorney are associated in the public’s mind with Ernesto Miranda, who was convicted of rape in Arizona in 1963. Our so-called Miranda rights came from the famous 1966 Supreme Court decision that overturned his conviction. However, the foundation for this landmark ruling was laid much earlier, all the way back in 1919, when a young Chinese man was accused of murdering three of his countrymen in Washington, D.C.

The victims worked for the Chinese Educational Mission and were assassinated in the city’s Kalorama neighborhood. The police zeroed in on a suspect in Manhattan, went up to his apartment, and forced the man to return to Washington with them. They held him incommunicado in a hotel room, with no formal arrest, reports Smithsonian Magazine. The young Chinese man, Ziang Sun Wan, was then effectively tortured and bullied into giving a confession. He recanted it during the trial, but the judge refused to exclude it and convicted him of first-degree murder. His appeal eventually made it to the Supreme Court. At this point, policemen detectives were using numerous “creative” methods for extracting confessions from suspects, most of which equated to physical or mental torture. These tactics sparked a debate about what kind of interrogations and police conduct should and should not be prohibited by law.

In writing the majority opinion for the 1966 case Miranda v. Arizona, Chief Justice Earl Warren quoted from Ziang Sung Wan v. United States, affirming that the Fifth Amendment permitted only voluntary confessions to be admitted as evidence.

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