Starting with the pioneering work of Edwin Borchard, the American focus has been on proven factual innocence. This concept has a populist appeal and fits with America’s moralistic and highly punitive approach to crime. Proven innocence has inspired both legislative reforms and executive grants of clemency. It has had somewhat less success with American courts. American Federal courts require proven innocence for some defaulted habeas corpus claims but have not recognized free-standing innocence claims. Death row exonerations have played a role in executive moratoriums and legislative abolition of the death penalty in some states but have not resulted in judicial abolition. Mass exonerations related to policing and forensic science scandals have received far less attention than the UK’s post office scandal even though they reveal much about false guilty pleas and systemic discrimination. Generous systems of legislative compensation and civil rights litigation are related to the popular appeal of proven innocence and successful civil right litigation. Finally, some possible future directions for American innocence projects and movements in light of Trump’s first presidency and his re-election in 2024 are assessed.

This chapter examines what is known about China’s remedied wrongful convictions including three well-publicized “back from the dead” cases. The predominant cause was false confessions obtained through police torture. As in the United States, remedied cases typically involved multiple rounds of litigation that establish proven or obvious innocence. China’s responses to well-publicized wrongful convictions from 2006 to 2013, including the introduction of an exclusionary rule for involuntary confessions, are assessed. These reforms may help legitimate or wrongful conviction wash an unjust system. Unremedied wrongful convictions may increase under a 2018 law to encourage guilty pleas. The precarious and marginal role of defence lawyers is examined. Compensation has increased for the wrongfully convicted and is available to the wrongfully detained. The extension of the authoritarian Chinese system would have regressive effects, given Hong Kong’s broader focus on miscarriages of justice and Taiwan’s more democratic approach and lesser reliance on guilty pleas.