Holmes v. South Carolina

Supreme Court of the United States · 2006 · Evidence

547 U.S. 319 (2006)

Updated August 1, 2026

Evidencethird-party guilt evidencethird-party guiltcomplete defensedue processSixth Amendmentarbitrary evidentiary rulesforensic evidence

Facts

At petitioner's second trial for the murder, rape, burglary, and robbery of Mary Stewart, the prosecution relied heavily on forensic evidence linking petitioner to the crime, along with testimony placing him near the victim's home around the time of the attack. Petitioner attacked the reliability of that forensic evidence by claiming contamination and a plot by law enforcement officers to frame him. He also sought to introduce evidence that another man, Jimmy McCaw White, was in the neighborhood and had made statements admitting or strongly implying that he committed the crime. The trial court excluded that third-party guilt evidence, and the South Carolina Supreme Court affirmed because it concluded the State's forensic case was too strong for the proffer to raise a reasonable inference of petitioner's innocence.

Issue

May a State exclude a criminal defendant's evidence of third-party guilt on the ground that the prosecution has introduced strong evidence of the defendant's guilt, especially strong forensic evidence? Does such a rule violate the defendant's constitutional right to present a complete defense?

Rule

Although states have broad latitude to adopt evidentiary rules, the Constitution forbids rules that exclude defense evidence in a way that infringes a weighty interest of the accused and is arbitrary or disproportionate to the purposes the rule is meant to serve. A rule excluding third-party guilt evidence based on the apparent strength of the prosecution's case, rather than on the defense evidence's own probative value or traditional risks such as prejudice, confusion, or remoteness, is arbitrary and unconstitutional.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a murder trial in Cleveland, the prosecution presents surveillance footage and fingerprint evidence that, if believed, strongly identifies Daniel Price as the shooter. Daniel offers testimony from two witnesses that Owen Mercer confessed to the shooting the next day and was seen running from the alley with a gun. The trial judge excludes the defense evidence solely because the State's forensic and video proof appears overwhelming.

Was the exclusion constitutional?

Explanation. The majority held that a rule making admissibility turn on the perceived strength of the prosecution's case is arbitrary. The proper focus is the defense evidence's own probative value and any traditional dangers like prejudice, confusion, or remoteness, not whether the State's proof looks strong if believed.