United States v. Wong
Headline: Court allows prosecution for lying in grand jury testimony despite ineffective Fifth Amendment warnings, reversing suppression and making it easier to use false testimony against witnesses with limited English.
Holding: The Court held that the Fifth Amendment does not protect a witness who lies before a grand jury, and inadequate warnings do not require suppression of false testimony in a later perjury prosecution.
- Allows prosecutors to use false grand jury testimony in later perjury trials.
- Means witnesses with limited English may still face perjury charges despite unclear warnings.
- Reversal lets previously suppressed perjury cases proceed under new guidance.
Summary
Background
A woman who emigrated from China and speaks limited English was called to testify before a federal grand jury investigating illegal gambling and alleged bribes to undercover police. Prosecutors warned her about the right not to incriminate herself, but a District Judge found she did not understand that warning. After she denied giving money to officers, she was later indicted for perjury. The District Court suppressed her grand jury testimony as involuntary, and a federal appeals court agreed that failing to give an effective warning made the procedure unfair.
Reasoning
The Court considered whether a lack of effective warning requires that knowingly false testimony be suppressed. It held that the Fifth Amendment’s protection against self-incrimination does not give a witness the right to lie under oath. The opinion relied on earlier decisions finding that false statements cannot be justified by claiming compulsion to avoid self-incrimination. The Court also rejected the idea that the unfairness of inadequate warnings means perjured testimony must be excluded. In short, even if the warning was ineffective, a witness may still be prosecuted for giving false testimony.
Real world impact
The ruling means prosecutors may use and prosecute false grand jury testimony even when a witness later shows they did not understand warnings, including witnesses with limited English. The case was reversed and sent back to the lower court for further proceedings consistent with this opinion, so prosecutions that were blocked by suppression orders may now proceed.
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