U.S. Supreme Court Strikes Down Rule Disallowing Evidence of a Third-Party's Guilt in a Criminal Trial
The United States Supreme Court struck down a South Carolina rule that allowed judges to ban evidence of third-party guilt when the prosecutor's evidence against a defendant is strong. See Holmes v. South Carolina. No. 04-1237 (May 1, 2006).
In Holmes v. South Carolina, the defendant was convicted of beating, raping, and murdering an elderly woman. How disturbing the crime was does not enter into the Supreme Court's review of a trial. In this case, the fairness of the trial was the only real issue before the court. Here, the prosecutor and the defense presented their evidence to the trial judge so he could determine what evidence the jury would see. The judge ruled the prosecutor's evidence could be introduced at trial, but the defense's evidence, showing a third-party may have committed the crime, was not allowed because the prosecution's evidence was convincing.
The prosecutor presented strong evidence against Holmes, including a palm print, fiber evidence, blood evidence, and a DNA match. The defense countered that police had planted evidence and mishandled the DNA evidence. More important to this Supreme Court case, the defense sought to introduce evidence that another person, Jimmy White, had been seen in the area, said Holmes was innocent, and had made statements indicating he had committed the crime.
Holmes appealed his conviction, but it was upheld by the South Carolina Supreme Court, saying that where there is strong evidence of a defendant's guilt, especially where there is strong forensic evidence, evidence about a third party's alleged guilt does not raise a reasonable doubt as to the defendant's own guilt. In other words, because the prosecutor had presented a convincing case, the defense was not allowed to present its side of the story.
While the United States Constitution gives states wide latitude to set their own rules of evidence, the Constitution guarantees criminal defendants "a meaningful opportunity to present a complete defense." This right is denied by rules that keep a defendant from presenting a meaningful defense. The Court stated that while state courts may exclude evidence if it is not meaningful, confuses the issues, or is intended to simply mislead the jury, state courts cannot disallow defense evidence simply because it argues against the prosecution's case.
The Court cited a rule from Texas forbidding testimony from an alleged participant in the same crime. A man charged with murder in Texas was not allowed to call, as a witness, the person who had already been convicted of the same murder. The defendant's conviction was overturned. Holmes' conviction was likewise overturned by the U.S. Supreme Court and his case was returned to the South Carolina courts for a proper trial.
