State v. Koedatich

In State v. Koedatich, 112 N.J. 225, 311-12, 548 A.2d 939 (1988), cert. denied, 488 U.S. 1017, 109 S. Ct. 813, 102 L. Ed. 2d 803 (1989), the defense unsuccessfully sought to introduce evidence at trial regarding the possible guilt of another in order to establish defendant's innocence. On appeal, the Supreme Court recognized that "an accused has a constitutional right under the due process clause of the fourteenth amendment to offer probative evidence tending to show that a third party committed the crime charged." Koedatich, supra, 112 N.J. at 297, 548 A.2d 939. However, the Court found that the trial court had not abused its discretion in finding that the proffered evidence insufficiently linked the third party to the victim and her murder and thus "did not have a rational tendency to engender a reasonable doubt with respect to an essential feature of the State's case." Koedatich, supra, 112 N.J. at 298, 311-12, 548 A.2d 939.