third-party guilt

Holmes v. South Carolina

Issues

By restricting a criminal defendant’s opportunity to present evidence that someone else is culpable, does South Carolina’s third-party guilt evidence rule violate criminal defendants’ Constitutional rights to a fair trial, due process, and opportunity to obtain and confront witnesses?

 

Bobby Lee Holmes was charged with murder and other crimes related to a 1989 assault on an eighty-six year old victim. At trial Holmes sought to introduce evidence suggesting that another man, Jimmy McCaw White, was the real killer. South Carolina’s “third-party guilt” rule, however, presented a significant burden that Holmes had to overcome before his evidence could be admitted. The trial court held that Holmes’ proffered evidence did not meet this standard because it merely cast a “bare suspicion” on White, and Holmes was found guilty and sentenced to death. On appeal the Supreme Court of South Carolina held that the trial court applied the correct legal standard for admitting third-party-guilt evidence and affirmed the conviction. The Supreme Court granted certiorari limited to the issue of the validity of the South Carolina rule.

Questions as Framed for the Court by the Parties

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?
At about 8:00 a.m. on December 31, 1989 police officers Dale Edwards, Lt. Barnett, and others responded to a report regarding an elderly woman who had been assaulted, raped, and robbed by a man who forced his way into her home. State v. Holmes, 361 S.C. 333, 336 (S.C. 2004). Before lapsing into mental confusion and eventually dying in March, the eighty-six year old victim told the police that the attack occurred around 6 a.m. Id at 337. She described her assailant as being dark skinned, “middle aged…young [but]…not too young”, and “not too heavy[,] not too slim.” Id.

Additional Resources

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