Holmes v. South Carolina,
547 U.S. 319 (2006)
In 1995, a South Carolina jury convicted and sentenced to death, petitioner, Bobby Lee Holmes, for the “murder, first-degree criminal sexual assault, first-degree burglary, and robbery,” of 86-year-old Mary Stewart. State v. Holmes, 320 S.C. 259, 262, 464 S.E. 2d 334, 336 (1995). The defendant sought to present evidence that another party committed the crimes for which he stood trial. Id. Holmes’ defense cited information from witnesses that the other party, Jimmy McCaw White, bragged about committing the crime, following the victim’s death. White denied this under oath, claiming an alibi, which other witnesses refuted. Additionally, the defense fervently argued police tainted forensic evidence with a sloppy investigation, and an attempt to frame the defendant for the murder. Holmes, v. South Carolina, (No. 04-1327), 361 S. C. 333, 605 S. E. 2d 19.
The trial court refused to allow the defense to enter the third-party evidence, citing State v. Gregory, 198 S. C. 98, 16 S. E. 2d 532 (1941). In Gregory, the court held that evidence of third-party guilt “is admissible if it ‘raise[s] a reasonable inference or presumption as to [the defendant’s] own innocence’ but it is not admissible if it merely ‘cast[s] a bare suspicion upon… another’… as to the commission of the crime by another’.’” The judge declared the seemingly overwhelming forensic evidence of the defendant’s guilt far outweighed any possible evidence another party committed the crimes. Holmes v. South Carolina, supra. On appeal, the South Carolina Supreme Court affirmed the trial court’s decision to exclude the evidence. Holmes v. S.C., Oyez Supreme Court Media, http://www.oyez.org/cases/2000-2009/2005/2005_04_1327/. The Supreme Court disagreed and granted certiorari. Holmes v. South Carolina, supra. II. Issue:
At issue in Holmes, is whether the South Carolina rulings, prohibiting evidence of third-party guilt, violated the defendant’s Fourteenth Amendment right to due process, and/or the compulsory process or confrontation clauses of the Sixth Amendment. Id. 1.
Does the defendant have a right to introduce evidence of guilt of a third party to uphold his Sixth and Fourteenth Amendment rights? 2.
If the defendant possesses the right to offer this evidence, and the courts violated that right, does the law provide a remedy to correct the violation? 3.
If the law provides a remedy, is it within the power of the Supreme Court to issue the writ of certiorari requested under that remedy? Decision and Action:
Yes. According to the Supreme Court, the defendant possesses the right to introduce
evidence of third-party guilt. To 2.
Yes, a writ of certiorari is the legal remedy provided by law. To 3.
Yes, the Supreme Court possesses lawful jurisdiction to grant certiorari, and vacates the ruling of the South Carolina Supreme Court remanding “the case for further proceedings” in line with the U.S. Supreme Court’s ruling. Holmes v. South Carolina, supra. Unanimous, 9-0: “Remanded.” Holmes v. South Carolina, supra. Rule: Landmark case establishing to refuse the defendant’s opportunity to introduce evidence of third-party guilt is in violation of the Fourteenth Amendment right to due process, and the compulsory process or confrontation… Sixth Amendment. Holmes v. South Carolina, supra. III. Analysis:
Justice Alito delivered the opinion of the court.
The Supreme Court previously held that the Constitution allows the courts “to exclude evidence that is ‘repetitive . . ., only marginally relevant’ or poses an undue risk of ‘harassment, prejudice, [or] confusion of the issues.’” Id. Specifically, this principle seeks to regulate admission of inconsequential evidence indicating someone other than the defendant committed the crime charged. Id. 2.
Federal Rules of Evidence hold that “evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of...
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