Wednesday, December 18, 2013

Holmes v. South Carolina case brief

Holmes v. South Carolina case brief summary
547 U.S. 319 (2006)

Petitioner criminal defendant was on trial for a combined rape and robbery. The trial court excluded defendant's third-party guilt evidence, and he was sentenced to death. The South Carolina Supreme Court found no error in the exclusion of the third-party guilt evidence holding that defendant could not overcome the forensic evidence against him to raise a reasonable inference of his own innocence. Certiorari was granted.


  • The Court held that under the rule applied by the South Carolina Supreme Court, the trial judge did not focus on the probative value or the potential adverse effects of admitting the defense evidence of third-party guilt. 
  • Instead, the critical inquiry concerned the strength of the prosecution's case; if the prosecution's case was strong enough, the evidence of third-party guilt was excluded even if that evidence, if viewed independently, would have had great probative value and even if it would not have posed an undue risk of harassment, prejudice, or confusion of the issues. 
  • Furthermore, the rule seemed to call for little, if any, examination of the credibility of the prosecution's witnesses or the reliability of its evidence. 
  • The Court held that the rule did not rationally serve the end that the Gregory rule was designed to promote, i.e., to focus the trial on the central issues by excluding evidence that had only a very weak logical connection to the central issues. 
  • Nor had the State identified any other legitimate end that the rule served. 
  • Therefore, the rule as applied in the case violated defendant's right to have a meaningful opportunity to present a complete defense.
The judgment of the South Carolina Supreme Court was vacated and the case was remanded for further proceedings.

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