legal brief holmes

Holmes v. South Carolina No.04-1327, Supreme Court of the United States. May 1, 2006.

Facts: Holmes was convicted of murder, first degree criminal sexual assault, first degree burglary and robbery, and was sentenced to death by a South Carolina jury. During his trial he motioned to have an expert witness give testimony refuting the credibility of the forensic evidence. Also, Holmes wanted to introduce evidence that another man was at the scene of the crime the morning of when it was committed and had said that he had committed the crime and that Holmes did not. The trial court excluded the third-party evidence stating it was inadmissible because it could not overcome the forensic evidence against him and it only merely casts a bare suspicion of another’s guilt.

Procedural History: Trial court convicted Holmes. Holmes appealed to the South Carolina Supreme Court and the Court gave cert. South Carolina Supreme Court upheld the trial court’s decision. Holmes appealed the U.S. Supreme Court. U.S. Supreme Court gave cert.

Issue: Whether someone’s constitutionally protected right to a fair trial is violated by an evidence rule that prohibits him from presenting evidence of a third party’s guilt if the prosecution has produced forensic evidence that if held true, heavily supports a guilty verdict.

Holding: Yes

Reasoning: The Constitution guarantees criminal defendants a meaningful opportunity to present a complete defense. There are well established evidence rules that exclude evidence if its probative value is outweighed by other concerns like unfair prejudice, it confuses the issues, or the potential to mislead the jury. This evidence however does not have a practical purpose because it only serves to benefit the prosecution and prevent any questions of the credibility of the prosecution’s evidence.

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