CONSTITUTIONAL LAW-RESTRICTING LIBERTY WITHOUT DUE PROCESS OF LAW-EXTORTED CONFESSIONS

Authors

Abstract

Of recent years the administration of criminal justice has increased many-fold, owing to the constantly increasing size of our great cities and the period of growing social unrest in which we find ourselves. Public opinion has demanded a more effective mode of dealing with those who break the law with seeming impunity. In view of this attitude it is only natural that in a particularly baffling crime the police should seek to obtain some clue of the criminals by grilling suspects. This has resulted in many cases in acts which to say the least are over-zealous. In a recent case one Ziang Sung Wan was suspected of the murder of three of his fellow-countrymen in Washington, D. C. He was found sick in bed in New York city by detectives and was taken to Washington. Instead of being lodged in jail, he was kept incommunicado in a remote hotel and grilled for hours at a time while still in a very serious condition. After nine days of questioning and constant pressure to make a statement, he was finally arrested and later signed the confession which effected his conviction on a charge of murder. On appeal the. United States Supreme Court held that the trial court had erred in admitting the statement as a voluntary confession. Ziang Sung Wan v. United States (Oct. 1924) Adv. Ops. 127, 45 Sup. Ct. 1.

Recommended Citation

CONSTITUTIONAL LAW-RESTRICTING LIBERTY WITHOUT DUE PROCESS OF LAW-EXTORTED CONFESSIONS, 23 Mich. L. Rev. 387 (1925).
Available at: https://repository.law.umich.edu/mlr/vol23/iss4/7