Legal Brief of Holmes v. South Carolina
Published 04 Aug 2016
The Petitioner, in this case, is Bobby Lee Holmes while the Respondent is South Carolina.
On December 31, 1989, an 86-year-old woman was beaten, raped and robbed in her home in South Carolina. She died the following year due to complications from her injuries. The South Carolina jury convicted Holmes of the crimes of murder, first-degree sexual conduct, first-degree burglary, robbery and sentenced Holmes to death. The convictions and sentence were affirmed by the South Carolina Supreme Court. US Supreme Court denied certiorari. Holmes was granted a new trial upon post-conviction review. During the second trial, the prosecution relied on forensic evidence such as the petitioner’s palm print found above the door knob of the victim’s house, fibers consistent with black sweatshirt owned by Holmes, blue fibers found on the victim’s nightgown and Holmes jeans, DNA of the victim found on the petitioner’s underwear, and victim’s blood found on Holmes’ tank top. Meanwhile, Holmes presented witnesses who claimed that the forensic evidence was contaminated in view of improper handling procedure. He also tried to introduce evidence that another man, Jimmy McCaw, had attacked the victim. At the pretrial hearing, Holmes presented witnesses who testified that they have seen White in the victim’s neighborhood on the morning of the attack and four other witnesses who said that White had previously admitted to committing the crime. Citing the case of State v. Gregory, the trial court excluded the petitioner’s third-party guilt evidence and said that it is admissible only if it raises a reasonable inference or presumption as to the defendant’s own innocence but it is not admissible if it merely casts a bare suspicion upon another or raises a conjectural inference as to the commission of crime by another. It added that when there is a strong evidence of guilt, especially when there is strong forensic evidence, the evidence of a third party’s alleged guilt does not raise a reasonable inference as to the appellant’s own innocence. It concluded that Holmes could not overcome the forensic evidence against him as to raise a reasonable inference of his own innocence.
The Supreme Court granted certiorari
- Law at Issue: the Law at issue here is the extent of the defendant’s right to due process and to introduce proof of third-party guilt.
- The Legal Question: whether constitutional rights are violated by an evidence rule that prohibits the defendant from introducing evidence proving third-party guilt if the prosecution has initially introduced forensic evidence that strongly supports a guilty verdict.
- Court Opinion and Holding: The US Supreme Court vacated and remanded the decision of the South Carolina Supreme Court. It ruled that while state and federal legislators have been given broad discretion to establish rules excluding evidence from criminal trials, this latitude is not absolute. The 14th Amendment and the 6th Amendment guarantee the criminal defendants’ right to present a complete defense. The right to present a complete defense is violated by arbitrary rules or rules that exclude important defense evidence which does not serve any legitimate interest.
The Supreme Court also recognized the well-established rules of evidence that permit judges to exclude evidence if its probative value is outweighed by unfair prejudice, confusion of the issues or potential to mislead the jury. Moreover, the Supreme Court also permit the exclusion of evidence that is repetitive marginally relevant and poses an undue risk of harassment. Despite this, the Supreme Court ruled that prohibiting the defendant from introducing evidence proving third-party guilt simply because the prosecution already has a strong evidence of defendant’s guilt is untenable as it focuses on the strength of the prosecution’s case instead of the probative value of defendant’s evidence. Thus, by focusing on the strength of the evidence of the prosecution, the defendant is thereby deprived of the opportunity to rebut or cast doubt on the evidence of the prosecution. This rule excluding evidence proving third-party guilt simply because the prosecution’s evidence is strong is arbitrary and in violation of the defendant’s right to be given the opportunity to present a complete defense.
The standard relied on or established in this case is the right of a defendant to have a meaningful defense.
The Supreme Court’s decision is consistent with the protection guaranteed by the due process clause which is that no person shall be deprived of life, liberty and property without due process of law. Due process is simply that which pertains to what is fair and right and just. It is simply the right to be heard and to be given the opportunity to present evidence on one’s behalf. Basic is the rule that accusation is not synonymous with guilt as such every person should no matter how strong the evidence against him should be given the opportunity to present evidence. This is why the constitution allows the defendant opportunity to present his defense which exculpates him from guilt or exonerates him from a greater degree of guilt or punishment. They are entitled to this right before any verdict is rendered by the court.