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Supreme Court Decision Update - Holmes v. South Carolina

supreme2.jpgThe first of today’s three Supreme Court decisions is Holmes v. South Carolina (PDF of the opinion) which is all about criminal defendants pointing the finger at a third-party as the one who “did it.”

QuizLaw Analysis: based on the Supremes’ analysis of this case, we would argue that it is your constitutional right to use the “whoever smelt it, dealt it” defense.

Here’s the background you need to know. A South Carolina man was put on trial for various crimes, including murder, following the gruesome beating and raping of an 86-year-old woman (who died as a result of her injuries). Holmes was convicted and sentenced to death. During the appeals process, he was granted a new trial, and during that second trial, the prosecution introduced forensic evidence which strongly supported a finding that Holmes was guilty (among other things, his palm print was at the crime scene, there were matching fibers, and there was DNA and blood evidence). In defending himself, Holmes wanted to introduce evidence that another man was actually responsible for the crime (Holmes was going to offer the testimony of several witnesses to support this position). During a pretrial hearing, however, the court excluded any evidence that the third-party had committed the crime, because a South Carolina Supreme Court decision had created a rule that essentially meant a criminal defendant could not introduce evidence suggesting a third-party was guilty if there is strong forensic evidence of the defendant’s guilt. As there was such forensic evidence in this case, the court ruled that Holmes could not introduce his evidence about the other man.

In a unanimous decision written by freshman Justice Alito, the Court held that the South Carolina rule violated criminal defendants’ constitutional rights. While state and federal rulemakers have broad powers in limiting what evidence can be used in criminal trials, these powers are not outweighed by the Due Process Clause of the Fourteenth Amendment or the Compulsory Process or Confrontation clauses of the Sixth Amendment, all of which guarantee criminal defendants the ability to provide a total defense during their trial. As such, evidence rules which are arbitrary or disproportionate to the alleged purpose they serve are unconstitutional, as they abridge these defendant rights. Now, there are evidence rules which forbid defendants from introducing evidence accusing others of the alleged crimes, and these rules have been found constitutionally valid. However, these rules only forbid such evidence when it does not have any “meat” to it - that is, when the defendant is just casting bare suspicious or raising conjectures. The South Carolina rule at issue here, however, is much broader than these constitutionally valid rules, forbidding evidence of third-party guilt even where that evidence is probative and potentially meaningful. Worse yet, the rule requires virtually no determination about whether the prosecutions’ forensic evidence and witness are reliable. Thus, the rule does not meet its purported purpose of excluding weak and illogical evidence to keep the trial focused, and it is therefore unconstitutional.