Holmes v. South Carolina
Encyclopedia
Holmes v. South Carolina, 547 U.S. 319
(2006), was a decision by the United States Supreme Court
involving the right of a criminal defendant
to present evidence
that a third party instead committed the crime. The Court vacated the rape and murder conviction in South Carolina
of a man who had been denied the opportunity to present evidence of a third party's guilt, because the trial court believed the prosecutor
's forensic evidence was too strong for the defendant's evidence to raise an inference of innocence. The Court ruled unanimously that this exclusion violated the right of a defendant to have a meaningful opportunity to present a complete defense, because the strength of a prosecutor's case had no logical relationship to whether a defendant's evidence was too weak to be admissible.
The opinion was delivered by Justice
Samuel Alito
, and was his first opinion as a member of the Court following his confirmation
on January 31, 2006. This follows a Supreme Court tradition that the first written opinion of a new justice reflect a unanimous decision. This case also marks the last time in five years that Clarence Thomas
spoke during oral argument
.
, and died the following year of complications stemming from her injuries. After a four day jury
trial in York County
Circuit Court
in 1993, Bobby Lee Holmes was convicted of the crime and sentenced to death
. The South Carolina Supreme Court affirmed his convictions and sentence, and the U.S. Supreme Court denied certiorari
. Holmes was granted a new trial, however, upon state postconviction review.
At the second trial, the prosecution relied heavily on forensic evidence that Holmes' palm print and fibers consistent with his clothing were found at the scene, that the victim's DNA
was found in Holmes' underwear and her blood was found on his tank top. The prosecution also introduced evidence that Holmes had been seen near the victim's home within an hour of when the prosecutor believed the attack took place.
As a major part of his defense, Holmes presented expert witness
es who claimed that the forensic evidence was contaminated by poor handling procedures, and that the palm print was planted by police who Holmes asserted were trying to frame
him. Holmes also tried to introduce proof that another man, Jimmy McCaw White, had actually attacked the victim. At a pretrial hearing
, Holmes had presented several witnesses who placed White in the victim's neighborhood on the morning of the attack, and four other witnesses who testified that White had admitted to committing the crime, or at least acknowledged that Holmes was innocent. White testified at the pretrial hearing and denied making the incriminating statements. He also provided an alibi
for the time of the crime, but this was refuted by another witness.
The trial court excluded Holmes' third-party guilt evidence based on State v. Gregory, 16 S.E.2d
532 (S.C. 1941), in which the South Carolina Supreme Court had held that such evidence is only admissible if it "raises a reasonable inference or presumption as to [the defendant's] own innocence." Holmes was subsequently convicted again. On appeal, the South Carolina Supreme Court affirmed the conviction, citing to both Gregory and its later decision in State v. Gay 541 S.E.2d 541 (S.C. 2001). The State Supreme Court held that "where there is strong evidence of an appellant's guilt, especially where there is strong forensic evidence, the proffered evidence about a third party's alleged guilt does not raise a reasonable inference as to the appellant's own innocence." Applying this standard, the court held that petitioner could not "overcome the forensic evidence against him to raise a reasonable inference of his own innocence." The U.S. Supreme Court granted certiorari
.
, the U.S. Supreme Court vacated and remanded the decision of the South Carolina Supreme Court. The Court ruled that the South Carolina rule of evidence
did not rationally serve the interest of "excluding evidence that has only a very weak logical connection to the central issues," because it was illogical to determine the weakness of a defendant's evidence by the strength of the prosecution's case.
Though state
and federal rulemakers have broad constitutional latitude to establish rules of evidence in criminal trials, this is limited by the guarantee that criminal defendants have "a meaningful opportunity to present a complete defense," a right protected by both the Compulsory Process Clause
of the Sixth Amendment
and the Due Process Clause of the Fourteenth Amendment
. This right is violated by rules of evidence that "infringe upon a weighty interest of the accused" and are arbitrary or "disproportionate to the purposes they are designed to serve." The Court had struck
several such arbitrary rules as unconstitutional in prior decisions.
Well-established rules of evidence permit trial judges to exclude defense evidence if its probative value is outweighed by its unfair prejudice, confusion of the issues, or potential to mislead the jury
. The Court noted that it had elaborated on this standard by permitting the exclusion of evidence that is "repetitive, only marginally relevant
or poses an undue risk of harassment, prejudice, or confusion of the issues." Rules regulating the admissibility of third-party guilt apply this principle, because this evidence is often too speculative or remotely associated with the crime. The Court observed that these rules are widely accepted, and were not in and of themselves being challenged in this case.
The Court believed the rule adopted by the South Carolina Supreme Court in Gregory to be of this kind, and to have been adapted from a rule presented in Corpus Juris Secundum
and American Jurisprudence
. However, the Court considered the later decision in State v. Gay and the instant case to represent a radical change and extension of the Gregory rule. In Gay, the South Carolina Supreme Court had ruled that the defendant's evidence could not raise a "reasonable inference" of his innocence "in view of the strong evidence" of his guilt, particularly the forensic evidence. Similarly, in the present case, the court applied the rule that "where there is strong evidence of [a defendant's] guilt, especially where there is strong forensic evidence, the proffered evidence about a third party's alleged guilt" may (or perhaps must) be excluded.
This rule was in error, the Court wrote, because it required the trial judge to focus on the strength of the prosecution's case instead of the probative value or the potential adverse effects of admitting the defense evidence of third-party guilt. The Court also believed that, as applied in this case, the rule did not seem to require any substantial examination of the credibility of the prosecution's witnesses or the reliability of its evidence. Holmes had argued that the forensic evidence was so unreliable that it should not have been admitted, yet in its evaluation of the "strength" of that evidence, the South Carolina Supreme Court made no mention of these defense challenges.
The Court stated that the rule was no more logical than if it were to instead exclude the prosecutor's evidence of the defendant's guilt if the defendant were able to present evidence that, if believed, strongly supported a not guilty verdict. "The point is that, by evaluating the strength of only one party's evidence, no logical conclusion can be reached regarding the strength of contrary evidence offered by the other side to rebut or cast doubt." The Court therefore found the rule to be "arbitrary" and in violation of a criminal defendant's right to have "a meaningful opportunity to present a complete defense."
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), was a decision by the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
involving the right of a criminal defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
to present evidence
Evidence (law)
The law of evidence encompasses the rules and legal principles that govern the proof of facts in a legal proceeding. These rules determine what evidence can be considered by the trier of fact in reaching its decision and, sometimes, the weight that may be given to that evidence...
that a third party instead committed the crime. The Court vacated the rape and murder conviction in South Carolina
South Carolina
South Carolina is a state in the Deep South of the United States that borders Georgia to the south, North Carolina to the north, and the Atlantic Ocean to the east. Originally part of the Province of Carolina, the Province of South Carolina was one of the 13 colonies that declared independence...
of a man who had been denied the opportunity to present evidence of a third party's guilt, because the trial court believed the prosecutor
Prosecutor
The prosecutor is the chief legal representative of the prosecution in countries with either the common law adversarial system, or the civil law inquisitorial system...
's forensic evidence was too strong for the defendant's evidence to raise an inference of innocence. The Court ruled unanimously that this exclusion violated the right of a defendant to have a meaningful opportunity to present a complete defense, because the strength of a prosecutor's case had no logical relationship to whether a defendant's evidence was too weak to be admissible.
The opinion was delivered by Justice
Associate Justice of the Supreme Court of the United States
Associate Justices of the Supreme Court of the United States are the members of the Supreme Court of the United States other than the Chief Justice of the United States...
Samuel Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
, and was his first opinion as a member of the Court following his confirmation
Samuel Alito Supreme Court nomination
On October 31, 2005, Samuel Alito was nominated by President George W. Bush for Associate Justice of the Supreme Court of the United States to replace the retiring Sandra Day O'Connor. Alito had been a judge on the United States Court of Appeals for the Third Circuit since 1990 when he was...
on January 31, 2006. This follows a Supreme Court tradition that the first written opinion of a new justice reflect a unanimous decision. This case also marks the last time in five years that Clarence Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
spoke during oral argument
Oral argument
Oral arguments are spoken presentations to a judge or appellate court by a lawyer of the legal reasons why they should prevail. Oral argument at the appellate level accompanies written briefs, which also advance the argument of each party in the legal dispute...
.
Background of the case
In 1989, an 86 year-old woman was beaten, raped, and robbed in her home in South CarolinaSouth Carolina
South Carolina is a state in the Deep South of the United States that borders Georgia to the south, North Carolina to the north, and the Atlantic Ocean to the east. Originally part of the Province of Carolina, the Province of South Carolina was one of the 13 colonies that declared independence...
, and died the following year of complications stemming from her injuries. After a four day jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
trial in York County
York County, South Carolina
York County is a county located in the north-central section of the U.S. state of South Carolina. According to the 2010 census, the county's population was 226,073. It is the second largest county in the Charlotte metropolitan area...
Circuit Court
South Carolina Circuit Court
The South Carolina Circuit Court is the state court of general jurisdiction of the U.S. state of South Carolina. It consists of a civil division and a criminal division ....
in 1993, Bobby Lee Holmes was convicted of the crime and sentenced to death
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
. The South Carolina Supreme Court affirmed his convictions and sentence, and the U.S. Supreme Court denied certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
. Holmes was granted a new trial, however, upon state postconviction review.
At the second trial, the prosecution relied heavily on forensic evidence that Holmes' palm print and fibers consistent with his clothing were found at the scene, that the victim's DNA
DNA
Deoxyribonucleic acid is a nucleic acid that contains the genetic instructions used in the development and functioning of all known living organisms . The DNA segments that carry this genetic information are called genes, but other DNA sequences have structural purposes, or are involved in...
was found in Holmes' underwear and her blood was found on his tank top. The prosecution also introduced evidence that Holmes had been seen near the victim's home within an hour of when the prosecutor believed the attack took place.
As a major part of his defense, Holmes presented expert witness
Expert witness
An expert witness, professional witness or judicial expert is a witness, who by virtue of education, training, skill, or experience, is believed to have expertise and specialised knowledge in a particular subject beyond that of the average person, sufficient that others may officially and legally...
es who claimed that the forensic evidence was contaminated by poor handling procedures, and that the palm print was planted by police who Holmes asserted were trying to frame
Frameup
A frame-up or setup is an American term referring to the act of framing someone, that is, providing false evidence or false testimony in order to falsely prove someone guilty of a crime....
him. Holmes also tried to introduce proof that another man, Jimmy McCaw White, had actually attacked the victim. At a pretrial hearing
Hearing (law)
In law, a hearing is a proceeding before a court or other decision-making body or officer, such as a government agency.A hearing is generally distinguished from a trial in that it is usually shorter and often less formal...
, Holmes had presented several witnesses who placed White in the victim's neighborhood on the morning of the attack, and four other witnesses who testified that White had admitted to committing the crime, or at least acknowledged that Holmes was innocent. White testified at the pretrial hearing and denied making the incriminating statements. He also provided an alibi
Alibi
Alibi is a 1929 American crime film directed by Roland West. The screenplay was written by West and C. Gardner Sullivan, who adapted the 1927 Broadway stage play, Nightstick, written by Elaine Sterne Carrington, J.C...
for the time of the crime, but this was refuted by another witness.
The trial court excluded Holmes' third-party guilt evidence based on State v. Gregory, 16 S.E.2d
South Eastern Reporter
The South Eastern Reporter and South Eastern Reporter Second are United States regional case law reporters. It is part of the National Reporter System created by John B...
532 (S.C. 1941), in which the South Carolina Supreme Court had held that such evidence is only admissible if it "raises a reasonable inference or presumption as to [the defendant's] own innocence." Holmes was subsequently convicted again. On appeal, the South Carolina Supreme Court affirmed the conviction, citing to both Gregory and its later decision in State v. Gay 541 S.E.2d 541 (S.C. 2001). The State Supreme Court held that "where there is strong evidence of an appellant's guilt, especially where there is strong forensic evidence, the proffered evidence about a third party's alleged guilt does not raise a reasonable inference as to the appellant's own innocence." Applying this standard, the court held that petitioner could not "overcome the forensic evidence against him to raise a reasonable inference of his own innocence." The U.S. Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
The Supreme Court's decision
In a unanimous decision by Justice Samuel AlitoSamuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
, the U.S. Supreme Court vacated and remanded the decision of the South Carolina Supreme Court. The Court ruled that the South Carolina rule of evidence
Evidence (law)
The law of evidence encompasses the rules and legal principles that govern the proof of facts in a legal proceeding. These rules determine what evidence can be considered by the trier of fact in reaching its decision and, sometimes, the weight that may be given to that evidence...
did not rationally serve the interest of "excluding evidence that has only a very weak logical connection to the central issues," because it was illogical to determine the weakness of a defendant's evidence by the strength of the prosecution's case.
Though state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
and federal rulemakers have broad constitutional latitude to establish rules of evidence in criminal trials, this is limited by the guarantee that criminal defendants have "a meaningful opportunity to present a complete defense," a right protected by both the Compulsory Process Clause
Compulsory Process Clause
The Compulsory Process Clause of the Sixth Amendment to the United States Constitution provides that "In all criminal prosecutions, the accused shall enjoy the right...to have compulsory process for obtaining witnesses in his favor."...
of the Sixth Amendment
Sixth Amendment to the United States Constitution
The Sixth Amendment to the United States Constitution is the part of the United States Bill of Rights which sets forth rights related to criminal prosecutions...
and the Due Process Clause of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
. This right is violated by rules of evidence that "infringe upon a weighty interest of the accused" and are arbitrary or "disproportionate to the purposes they are designed to serve." The Court had struck
Judicial review
Judicial review is the doctrine under which legislative and executive actions are subject to review by the judiciary. Specific courts with judicial review power must annul the acts of the state when it finds them incompatible with a higher authority...
several such arbitrary rules as unconstitutional in prior decisions.
Well-established rules of evidence permit trial judges to exclude defense evidence if its probative value is outweighed by its unfair prejudice, confusion of the issues, or potential to mislead the jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
. The Court noted that it had elaborated on this standard by permitting the exclusion of evidence that is "repetitive, only marginally relevant
Relevance (law)
Relevance, in the common law of evidence, is the tendency of a given item of evidence to prove or disprove one of the legal elements of the case, or to have probative value to make one of the elements of the case likelier or not. Probative is a term used in law to signify "tending to prove."...
or poses an undue risk of harassment, prejudice, or confusion of the issues." Rules regulating the admissibility of third-party guilt apply this principle, because this evidence is often too speculative or remotely associated with the crime. The Court observed that these rules are widely accepted, and were not in and of themselves being challenged in this case.
The Court believed the rule adopted by the South Carolina Supreme Court in Gregory to be of this kind, and to have been adapted from a rule presented in Corpus Juris Secundum
Corpus Juris Secundum
Corpus Juris Secundum is an encyclopedia of U.S. law . Its full title is Corpus Juris Secundum: Complete Restatement Of The Entire American Law As Developed By All Reported Cases It contains an alphabetical arrangement of legal topics as developed by U.S...
and American Jurisprudence
American Jurisprudence
American Jurisprudence is an encyclopedia of United States law, published by West. It was originated by Lawyers Cooperative Publishing, which was subsequently acquired by the Thomson Corporation. The series is now in its second edition, launched in 1962...
. However, the Court considered the later decision in State v. Gay and the instant case to represent a radical change and extension of the Gregory rule. In Gay, the South Carolina Supreme Court had ruled that the defendant's evidence could not raise a "reasonable inference" of his innocence "in view of the strong evidence" of his guilt, particularly the forensic evidence. Similarly, in the present case, the court applied the rule that "where there is strong evidence of [a defendant's] guilt, especially where there is strong forensic evidence, the proffered evidence about a third party's alleged guilt" may (or perhaps must) be excluded.
This rule was in error, the Court wrote, because it required the trial judge to focus on the strength of the prosecution's case instead of the probative value or the potential adverse effects of admitting the defense evidence of third-party guilt. The Court also believed that, as applied in this case, the rule did not seem to require any substantial examination of the credibility of the prosecution's witnesses or the reliability of its evidence. Holmes had argued that the forensic evidence was so unreliable that it should not have been admitted, yet in its evaluation of the "strength" of that evidence, the South Carolina Supreme Court made no mention of these defense challenges.
The Court stated that the rule was no more logical than if it were to instead exclude the prosecutor's evidence of the defendant's guilt if the defendant were able to present evidence that, if believed, strongly supported a not guilty verdict. "The point is that, by evaluating the strength of only one party's evidence, no logical conclusion can be reached regarding the strength of contrary evidence offered by the other side to rebut or cast doubt." The Court therefore found the rule to be "arbitrary" and in violation of a criminal defendant's right to have "a meaningful opportunity to present a complete defense."