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Monday, May 01, 2006

Holmes v. South Carolina: Right to Put on Defense

In Holmes v. South Carolina, No. 04-1327 (May 1, 2005), the Supreme Court held that a criminal defendant’s federal constitutional rights are violated by an evidence rule under which the defendant may not introduce evidence of third-party guilt if the prosecution has introduced forensic evidence that strongly supports a guilty verdict.
The Court noted that the Constitution guarantees criminal defendants the right to present a complete defense. Thus, while evidence rules could keep defendants from putting on evidence of third-party guilt where it does not sufficiently connect the person with the crime, the South Carolina rule applied to Holmes was different. The South Carolina rule focussed on the strength of the prosecution’s case. "[W]here the credibility of the prosecution’s witnesses or the reliability of its evidence is not conceded, the strength of the prosecution’s case cannot be assessed without making the sort of factual findings that have usually been reserved for the trier of fact and that the South Carolina courts did not purport to make in this case."
The Court added that disallowing a defense based on the strength of the prosecution’s case would have as little sense as not allowing the prosecution to put on a case if the defense appeared strong. By evaluating only one side’s evidence, the South Carolina rule was "arbitrary."