Holmes V. South Carolina Case Brief

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Holmes v. South Carolina
United States Supreme Court 547 U.S. 319 (2006)
Holmes was charged with first degree murder, first degree burglary and robbery in connection with an incident involving an 86 year old woman, Mary Stewart. Holmes was also charged for the rape and murder of Stewart. At the trial court, Holmes was convicted by the South Carolina Supreme Court. The United States Supreme Court denied certiorari. The petitioner had appealed and the court granted a new trail. During the new trial the prosecution introduced new forensic evidence including palm prints and blood that was found at the scene of the crime. At the new trial, the petitioner also sought to introduce proof of another man named Jimmy McCaw White. The court excluded the third party evidence of guilt because the grounds of the evidence were not admissible. The evidenced only implicated that the third party and did not exclude the defendant. The United States Supreme Court granted certiorari Issue:

Is evidence of a third party’s guilt admissible if it only implicates the third party and does not exculpate the defendant?

Rule and Rationale:
Yes. Under the Constitution of the United States, a defendant in a criminal case has to be given the opportunity to present a complete defense. The defendant also has the right and opportunity to present evidence of innocence, and only the evidence of guilt of a third party. Excluding evidence and only hearing the prosecutions evidence in the case did not give the court the right to make a conclusion based on the evidence at hand. The evidence against the prosecution supported that the defendant was guilty but did not automatically exclude the evidence of the third party as weak. Holmes was entitled to introduce the evidence of Whites guilt. The exclusion of that evidence violated Holmes's right to have the opportunity to present a complete defense.

Standard Relied On:
State v. Gay, 541 S.E.2d 541, 545 (S.C. 2001).
The case gave...
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