Holmes v. South Carolina

2006

Venue: SCOTUS

Facts: An old lady is beaten, raped, and robbed. She dies. The state prosecutes Holmes, and has lots of forensic evidence. Holmes wants to undermine the evidence, and suggest that another person had committed the crime; the trial court excludes this evidence.

Posture: Convicted at trial, affirmed on appeal. New trial on postconviction review. (convicted again, affirmed again?)

Issue: If the state has introduced forensic evidence which, if believed, strongly supports a guilty verdict, does it violate the defendant's constitutional rights to block the introduction of evidence supporting third-party guilt?

Holding: Yes. Vacated and remanded.

Rule: The true strength of the prosecution's proof cannot be assessed without considering challenges to the reliability of the prosecution's evidence.

Reasoning: Infringing on the right to present a complete defense has to have a strong rational basis. Evidence about third-party guilt has to be more than just assertion-- there must be enough to give rise to a reasonable inference. Still, it's not fair to exclude defense evidence just because the prosecution's evidence is strong.

Dicta: