State v. Holmes

Supreme Court of South Carolina · 2004 · Evidence

361 S.C. 333 (2004)

Updated August 22, 2026

EvidenceThird-party guiltreasonable inference of innocencebare suspicionconjectural inferenceforensic evidenceadmissibilityweight vs admissibility

Facts

The victim was attacked in her apartment by a black male who beat, raped, and robbed her, and she later died from pneumonia resulting from her severe brain injury. The State introduced substantial forensic evidence linking appellant to the crime, including his palm print on the interior side of the victim's front door, fibers consistent with his clothing on the victim's sheets and nightgown, DNA evidence from his underwear, and a blood mixture from appellant and the victim on his tank top. Appellant denied ever being inside the victim's apartment and sought to introduce evidence that another man, Jimmy McCaw White, committed the crimes. His proffer included witnesses placing Jimmy in the neighborhood and witnesses claiming Jimmy admitted appellant was innocent or admitted his own guilt.

Issue

Did the circuit court err by refusing to admit appellant's proffered evidence that Jimmy McCaw White committed the crimes? More specifically, did the proffered third-party-guilt evidence raise a reasonable inference of appellant's innocence in light of the State's evidence?

Rule

Evidence offered by an accused to show that another person committed the crime must be limited to facts inconsistent with the accused's own guilt and to facts that raise a reasonable inference or presumption of the accused's innocence. Evidence that has no effect other than to cast a bare suspicion on another person or raise only a conjectural inference that another committed the crime is not admissible. Further, where there is strong evidence of the defendant's guilt, especially strong forensic evidence, proffered third-party-guilt evidence does not raise a reasonable inference of the defendant's innocence.

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

In a murder trial in Columbia, defendant Marcus Vann denies ever entering the victim's townhouse. The prosecution offers Marcus's fingerprint from the inside of the back door, DNA from the victim and Marcus on his undershirt, and fibers matching Marcus's jacket on the victim's bedding. Marcus seeks to call two neighbors who saw Darnell Price walking on the victim's block at dawn and one witness who says Darnell once shrugged and said, "people blame the wrong guy all the time."

Should the trial court admit Marcus's third-party-guilt evidence?

Explanation. A defendant's evidence that another person committed the crime must be limited to facts inconsistent with the defendant's guilt and must raise a reasonable inference or presumption of the defendant's innocence. Evidence that merely casts bare suspicion or creates a conjectural inference is inadmissible. Where the State has strong evidence of guilt, especially strong forensic evidence, the proffer does not create the required reasonable inference of innocence.