HOLMES V. SOUTH CAROLINA
547 U.S 319 (2006)
NATURE OF THE CASE: Holmes (D) was convicted by a South Carolina jury of murder,
first-degree criminal sexual conduct, first-degree burglary, and robbery, and he was
sentenced to death. This conviction was affirmed. Upon state post-conviction review, D was
granted a new trial where the trial court excluded D's evidence of third party guilt because
it cast a bare suspicion or raised a conjectural inference as to another's guilt. D was
found guilty and the State Supreme Court affirmed holding that where there is strong
forensic evidence of a defendant's guilt, proffered evidence about a third party's alleged
guilt does not raise a reasonable inference as to the appellant's own innocence, the
evidence should be excluded. The Supreme Court granted certiorari.
FACTS: Mary Stewart, 86-year-old, was beaten, raped, and robbed in her home. She later
died of complications stemming from her injuries. D was convicted and sentenced to death. D
was granted a new trial on post-conviction review. At the second trial, the prosecution
entered forensic evidence that D was in fact the perpetrator including DNA evidence that D
committed the crime. D attempted to undermine the State's forensic evidence by suggesting
that the evidence had been contaminated and that certain law enforcement officers had
engaged in a plot to frame him. D's expert witnesses criticized the procedures used by the
police in handling the fiber and DNA evidence and in collecting the fingerprint evidence.
Another defense expert provided testimony that D cited as supporting his claim that the palm
print had been planted by the police. D sought to introduce proof that another man, Jimmy
McCaw White, had attacked Stewart. D proffered several witnesses who placed White in the
victim's neighborhood on the morning of the assault, as well as four other witnesses who
testified that White had either acknowledged that D was ' 'innocent' ' or had actually
admitted to committing the crimes. One witness recounted an admission by White. Another
witness, who had been incarcerated with White, testified that White had admitted to
assaulting Stewart, that a police officer had asked the witness to testify falsely against
D, and that employees of the prosecutor's office, while soliciting the witness' cooperation,
had spoken of manufacturing evidence against petitioner. White testified at the pretrial
hearing and denied making the incriminating statements. He also provided an alibi for the
time of the crime, but another witness refuted his alibi. The trial court excluded
petitioner's third-party guilt evidence because it determined that the evidence merely '
'cast[s] a bare suspicion upon another' ' or ' 'raise[s] a conjectural inference as to the
commission of the crime by another.' 'The South Carolina Supreme Court found no error
because there was strong evidence of D's guilt and the evidence about White did not raise a
reasonable inference as to D's own innocence.' The Supreme Court granted certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
Get
free access to the entire content for Mac, PC or Online
for 2-3 days and free samples
of all kinds of products.
for 2-3 days and free samples of all kinds of products.
https://bsmsphd.com
© 2007-2016 Abn Study Partner
No comments:
Post a Comment