''Holmes v. South Carolina'', 547 U.S. 319 (2006), was a decision by the
United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
involving the right of a criminal
defendant
In court proceedings, a defendant is a person or object who is the party either accused of committing a crime in criminal prosecution or against whom some type of civil relief is being sought in a civil case.
Terminology varies from one jurisdic ...
to present
evidence
Evidence for a proposition is what supports this proposition. It is usually understood as an indication that the supported proposition is true. What role evidence plays and how it is conceived varies from field to field.
In epistemology, evidenc ...
that a third party instead committed the crime. The Court vacated the rape and murder conviction in
South Carolina
)''Animis opibusque parati'' ( for, , Latin, Prepared in mind and resources, links=no)
, anthem = " Carolina";" South Carolina On My Mind"
, Former = Province of South Carolina
, seat = Columbia
, LargestCity = Charleston
, LargestMetro = ...
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
A prosecutor is a legal representative of the prosecution in states with either the common law adversarial system or the Civil law (legal system), civil law inquisitorial system. The prosecution is the legal party responsible for presenting the ...
's
forensic evidence
Forensic identification is the application of forensic science, or "forensics", and technology to identify specific objects from the trace evidence they leave, often at a crime scene or the scene of an accident. Forensic means "for the courts".
Hu ...
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
Justice, in its broadest sense, is the principle that people receive that which they deserve, with the interpretation of what then constitutes "deserving" being impacted upon by numerous fields, with many differing viewpoints and perspective ...
Samuel Alito
Samuel Anthony Alito Jr. ( ; born April 1, 1950) is an American lawyer and jurist who serves as an associate justice of the Supreme Court of the United States. He was nominated by President George W. Bush on October 31, 2005, and has served ...
, 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. Also, this case had marked the last time in ten years that
Clarence Thomas
Clarence Thomas (born June 23, 1948) is an American jurist who serves as an associate justice of the Supreme Court of the United States. He was nominated by President George H. W. Bush to succeed Thurgood Marshall and has served since 199 ...
had asked a question during
oral argument
Oral arguments are spoken presentations to a judge or appellate court by a lawyer (or parties when representing themselves) of the legal reasons why they should prevail. Oral argument at the appellate level accompanies written briefs, which also ad ...
. This period of silence lasted until shortly after the death of
Antonin Scalia
Antonin Gregory Scalia (; March 11, 1936 – February 13, 2016) was an American jurist who served as an associate justice of the Supreme Court of the United States from 1986 until his death in 2016. He was described as the intellectu ...
, with the oral argument during ''
Voisine v. United States''.
Background
In 1989, an 86-year-old woman was beaten, raped, and robbed in her home in
South Carolina
)''Animis opibusque parati'' ( for, , Latin, Prepared in mind and resources, links=no)
, anthem = " Carolina";" South Carolina On My Mind"
, Former = Province of South Carolina
, seat = Columbia
, LargestCity = Charleston
, LargestMetro = ...
, and died the following year of complications stemming from her injuries. After a four-day
jury
A jury is a sworn body of people (jurors) convened to hear evidence and render an impartiality, impartial verdict (a Question of fact, finding of fact on a question) officially submitted to them by a court, or to set a sentence (law), penalty o ...
trial in
York County Circuit Court in 1993, Bobby Lee Holmes was convicted of the crime and sentenced to
death
Death is the irreversible cessation of all biological functions that sustain an organism. For organisms with a brain, death can also be defined as the irreversible cessation of functioning of the whole brain, including brainstem, and brain ...
. The
South Carolina Supreme Court
The South Carolina Supreme Court is the highest court in the U.S. state of South Carolina. The court is composed of a Chief Justice and four Associate Justices. affirmed his convictions and sentence, and the
U.S. Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
denied
certiorari
In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
. Holmes was granted a new trial, however, upon state
postconviction review.
At the second trial, the prosecution relied heavily on
forensic evidence
Forensic identification is the application of forensic science, or "forensics", and technology to identify specific objects from the trace evidence they leave, often at a crime scene or the scene of an accident. Forensic means "for the courts".
Hu ...
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
An expert witness, particularly in common law countries such as the United Kingdom, Australia, and the United States, is a person whose opinion by virtue of education, training, certification, skills or experience, is accepted by the judge as ...
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
A frame is often a structural system that supports other components of a physical construction and/or steel frame that limits the construction's extent.
Frame and FRAME may also refer to:
Physical objects
In building construction
*Framing (con ...
him. Holmes also tried to introduce proof that another man, Jimmy McCaw White, had actually attacked the victim. At a pretrial
hearing
Hearing, or auditory perception, is the ability to perceive sounds
In physics, sound is a vibration that propagates as an acoustic wave, through a transmission medium such as a gas, liquid or solid.
In human physiology and psycholog ...
, 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
An alibi (from the Latin, '' alibī'', meaning "somewhere else") is a statement by a person, who is a possible perpetrator of a crime, of where they were at the time a particular offence was committed, which is somewhere other than where the crim ...
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
he defendant's
He or HE may refer to:
Language
* He (pronoun), an English pronoun
* He (kana), the romanization of the Japanese kana へ
* He (letter), the fifth letter of many Semitic alphabets
* He (Cyrillic), a letter of the Cyrillic script called ''He'' in ...
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
In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...
.
Opinion of the Court
In a unanimous decision by Justice
Samuel Alito
Samuel Anthony Alito Jr. ( ; born April 1, 1950) is an American lawyer and jurist who serves as an associate justice of the Supreme Court of the United States. He was nominated by President George W. Bush on October 31, 2005, and has served ...
, the
U.S. Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
vacated and
remanded the decision of the South Carolina Supreme Court. The Court ruled that the South Carolina rule of
evidence
Evidence for a proposition is what supports this proposition. It is usually understood as an indication that the supported proposition is true. What role evidence plays and how it is conceived varies from field to field.
In epistemology, evidenc ...
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
State may refer to:
Arts, entertainment, and media Literature
* ''State Magazine'', a monthly magazine published by the U.S. Department of State
* ''The State'' (newspaper), a daily newspaper in Columbia, South Carolina, United States
* ''Our S ...
and
federal
Federal or foederal (archaic) may refer to:
Politics
General
*Federal monarchy, a federation of monarchies
*Federation, or ''Federal state'' (federal system), a type of government characterized by both a central (federal) government and states or ...
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
The Compulsory Process Clause within the Sixth Amendment to the United States Constitution lets criminal case defendants attain witnesses in their favor by way of a court-ordered subpoena. The Clause is generally interpreted as letting defendants ...
of the
Sixth Amendment and the
Due Process Clause
In United States constitutional law, a Due Process Clause is found in both the Fifth and Fourteenth Amendments to the United States Constitution, which prohibits arbitrary deprivation of "life, liberty, or property" by the government except as ...
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
A jury is a sworn body of people (jurors) convened to hear evidence and render an impartiality, impartial verdict (a Question of fact, finding of fact on a question) officially submitted to them by a court, or to set a sentence (law), penalty o ...
. The Court noted that it had elaborated on this standard by permitting the exclusion of evidence that is "repetitive, only marginally
relevant
Relevant is something directly related, connected or pertinent to a topic; it may also mean something that is current.
Relevant may also refer to:
* Relevant operator, a concept in physics, see renormalization group
* Relevant, Ain, a commune ...
or poses an undue risk of harassment, prejudice, or confusion of the issues". (Internal marks and citations omitted.) 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'' (''CJS''; Latin for 'Second Body of the Law')Legal Research and Writing for Paralegals, Published by Wolters Kluwer and written by Deborah E. Bouchoux is an encyclopedia of United States law at the federal and state levels ...
'' and ''
American Jurisprudence
''American Jurisprudence'' (second edition is cited as Am. Jur. 2d) is an encyclopedia of the United States law, published by West. It was originated by Lawyers Cooperative Publishing, which was subsequently acquired by the Thomson Corporation. Th ...
''. 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
defendant'sguilt, especially where there is strong forensic evidence, the proffered evidence about a third party's alleged guilt" may (or perhaps must) be excluded.
[''Holmes'', 605 S.E.2d at 24.]
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".
Footnotes
External links
*
Transcript of oral argument(.pdf)
{{DEFAULTSORT:Holmes V. South Carolina
United States Supreme Court cases
United States Supreme Court cases of the Roberts Court
2006 in United States case law
United States criminal due process case law
Legal history of South Carolina