Holmes v. South Carolina
Holmes was convicted of multiple crimes, including first degree murder, and sentenced to death. At his trial, the court did not allow Holmes to present evidence that a third party had committed the crimes he had been charged with. The South Carolina Supreme Court affirmed on appeal, applying the rule that evidence of third party guilt must create a reasonable inference of innocence and be limited to facts that are inconsistent with the defendant’s own guilt. Where there is strong forensic evidence indicating the defendant’s guilt, casting a bare suspicion of guilt on a third party is insufficient to create a reasonable inference of the defendant’s innocence. Holmes did not meet the test for introducing evidence of third party guilt because of the strong forensic evidence against him.
Question Presented:
Whether a state's rule governing admissibility of third-party guilt evidence violates a criminal defendant's constitutional right to present a complete
defense grounded in due process, confrontation, and compulsory process clauses?
