Holmes v. South Carolina

PETITIONER: Bobby Lee Holmes
RESPONDENT: South Carolina
LOCATION: Board of Immigration Appeals

DOCKET NO.: 04-1327
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: South Carolina Supreme Court

CITATION: 547 US 319 (2006)
GRANTED: Sep 27, 2005
ARGUED: Feb 22, 2006
DECIDED: May 01, 2006

ADVOCATES:
John H. Blume - argued the cause for Petitioner
Steffen N. Johnson - argued the cause for Respondent

Facts of the case

Bobby Lee Holmes was sentenced to death after he was convicted of murder and several other crimes. At trial, he was not permitted to introduce evidence suggesting that another person had committed the crimes.

Under South Carolina law, defendants "seeking to present evidence of third-party guilt must [limit the evidence] to such facts as are inconsistent with his own guilt, and to such facts as raise a reasonable inference or presumption as to his own innocence." Evidence that merely casts a bare suspicion on another person is not admissible. Using this standard, the South Carolina Supreme Court affirmed the trial court's decision not to allow the evidence.

Question

Does South Carolina's rule governing the admissibility of evidence of third-party guilt violate a defendant's Fourteenth Amendment right to due process and Sixth Amendment rights to confrontation and compulsory process (the ability to compel witnesses to testify)?

Media for Holmes v. South Carolina

Audio Transcription for Oral Argument - February 22, 2006 in Holmes v. South Carolina

Audio Transcription for Opinion Announcement - May 01, 2006 in Holmes v. South Carolina

Justice Alito has the opinion in 04-1327, Holmes versus South Carolina.

Samuel A. Alito, Jr.:

This case comes to us on writ of certiorari to the Supreme Court of South Carolina.

At petitioner’s South Carolina trial for the murder of 86-year-old Mary Stewart, the prosecution relied heavily on forensic evidence that strongly supported petitioner’s guilt.

Petitioner attempted to undermine the forensic evidence, and he introduced evidence that another man had attacked Stewart.

The trial court excluded petitioner’s third-party guilt evidence, and the South Carolina Supreme Court affirmed.

Citing both its decisions in Gregory and Gay, it held that where there is strong forensic evidence of the defendant’s guilt, proffered evidence about a third-party’s alleged guilt does not raise a reasonable inference as to the defendant’s own innocence.

In an opinion filed with the Clerk today, we vacate the judgment of the South Carolina Supreme Court and remand the case for further proceedings.

The Constitution guarantees criminal defendants a meaningful opportunity to present a complete defense; that’s from Crane vs. Kentucky.

This right is abridged by evidence rules that are arbitrary or disproportionate to the purposes they are designed to serve.

But well-established evidence rules permit trial judges to exclude evidence if its probative value is outweighed by unfair prejudice, confusion of the issues or potential to mislead the jury.

An example of this is found in rules regulating the admission of third-party guilt, rules which are widely accepted and not challenged here.

In Gregory, the State Supreme Court adopted and applied a rule intended to be of this type.

In Gay and this case, however, the Court radically changed and extended the Gregory rule.

Under this new rule, the trial judge does not focus on the probative value or the potential adverse effects of the third-party guilt evidence; instead, if the prosecution’s case is strong enough, the third-party guilt evidence is excluded, even if independently it would have great probative value and would not pose an undue risk of harassment, prejudice or confusion.

This rule seems to call for little, if any, examination of the creditability of the prosecution’s witnesses or the reliability of its evidence, and by evaluating the strength of only one party’s evidence, no logical conclusion can be reached regarding the strength of contrary evidence offered to rebut or cast doubt.

The rule is arbitrary in the sense that it does not rationally serve the end that other third-party guilt rules were designed to further, and the State has not identified any other legitimate end served by the rule.

The rule thus violates a criminal defendant’s right to have a meaningful opportunity to present a complete defense.

The opinion of the Court is unanimous.