Holmes v. South Carolina

In Holmes v. South Carolina (2006), 547 U.S. 319, 126 S. Ct. 1727, 1731, 164 L. Ed. 2d 503, the United States Supreme Court vacated a State Supreme Court interpretation of a state evidentiary rule that precluded the accused from offering statements alleging third-party guilt because the statements were contrary to the prosecution's forensic evidence, which implicated the defendant. Id. at 1730-1731. The Holmes court concluded that such a construction of the rule ignored the probative value of the proffered evidence, and discounted the fact-finder's role in weighing the credibility of witnesses. Id. at 1733-1734. Instead of performing an independent examination of all the evidence in the case, the Holmes court found that the lower court's inquiry focused only on the strength of the prosecution's case--if the prosecution's case is strong enough, evidence of third-party guilt is per se excluded, even if that evidence would have great probative value when viewed independently of the conflicting evidence, and even if it prevented the defendant from his constitutional right to present a fair defense. Id. at 1734. Holmes was on trial for rape and murder, which ultimately resulted in his conviction and sentence to death, despite the fact Holmes offered witnesses who would have testified that they saw another man in the area near the time of the attack and that this other man had made statements implicating himself in the murder.