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Holmes v. South Carolina

Docket No.: 04-1327
Certiorari Granted: 9/27/2005
Argued: February 22, 2006
Decided: May 1, 2006

Topics:

Due Process, Miscellaneous

PartyNames: Bobby Lee Holmes v. South Carolina
Petitioner: Bobby Lee Holmes
Respondent: South Carolina

Court Below: Supreme Court of South Carolina

Bobby Lee Holmes
v.
South Carolina
547 U.S. 319 (2006)
Background:

In South Carolina, a criminal defendant's evidence of third-party guilt is inadmissible if, when comparing this evidence standing alone against the prosecution's evidence, the trial court finds that it fails to create a reasonable inference of innocence. In making this comparison, if the trial court finds the prosecution's evidence -- and especially its forensic evidence -- to be "strong," third-party guilt evidence is per se inadmissible because it is deemed, as a matter of law, to be insufficient to "overcome" the prosecution's evidence so as to create a reasonable inference of innocence.

Consideration Limited:

LIMITED TO QUESTION 1 PRESENTED BY THE PETITION.

Question Presented:

1. Whether South Carolina's rule governing the admissibility of third-party guilt evidence violates a criminal defendant's constitutional right to present a complete defense grounded in the Due Process, Confrontation, and Compulsory Process Clauses? 2. Whether a capital defendant is denied due process when a prosecutor successfully moves for the exclusion of third-party guilt evidence and then, in closing argument, urges the jury to find the defendant guilty because of the absence of such evidence?

Question:

Does South Carolina's rule governing the admissibility of evidence of third- party guilt violate a defendant's Fourteenth Amendment right to due process and Sixth Amendment rights to confrontation and compulsory process (the ability to compel witnesses to testify)?

Holding: vacated and remanded
Vote: 9-0
Opinion By:
Read HOLMES V. SOUTH CAROLINA opinion (PDF)
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