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Holmes v. South Carolina
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Holmes v. South Carolina : ウィキペディア英語版
Holmes v. South Carolina

''Holmes v. South Carolina'', 547 U.S. 319 (2006), was a decision by the United States Supreme Court involving the right of a criminal defendant to present evidence that a third party instead committed the crime. The Court vacated the rape and murder conviction in South Carolina of a man who had been denied the opportunity to present evidence of a third party's guilt, because the trial court believed the prosecutor's forensic evidence was too strong for the defendant's evidence to raise an inference of innocence. The Court ruled unanimously that this exclusion violated the right of a defendant to have a meaningful opportunity to present a complete defense, because the strength of a prosecutor's case had no logical relationship to whether a defendant's evidence was too weak to be admissible.
The opinion was delivered by Justice Samuel Alito, and was his first opinion as a member of the Court following his confirmation on January 31, 2006. This follows a Supreme Court tradition that the first written opinion of a new justice reflect a unanimous decision. This case also marks the last time in six years that Clarence Thomas spoke during oral argument.〔Liptak, Adam ("No Argument: Thomas Keeps 5-Year Silence" ), ''The New York Times'', February 12, 2011, accessed February 13, 2011〕
== Background ==
In 1989, an 86-year-old woman was beaten, raped, and robbed in her home in South Carolina, and died the following year of complications stemming from her injuries. After a four day jury trial in York County Circuit Court in 1993, Bobby Lee Holmes was convicted of the crime and sentenced to death. The South Carolina Supreme Court affirmed his convictions and sentence,〔''State v. Holmes'', 464 S.E. 2d 334 (S.C. 1995).〕 and the U.S. Supreme Court denied certiorari.〔Cert. denied, ''Holmes v. South Carolina'', 517 U.S. 1248 (1996).〕 Holmes was granted a new trial, however, upon state postconviction review.
At the second trial,〔The second trial was also held in York County Circuit Court, Judge John C. Hayes, III presiding.〕 the prosecution relied heavily on forensic evidence that Holmes' palm print and fibers consistent with his clothing were found at the scene, that the victim's DNA was found in Holmes' underwear and her blood was found on his tank top. The prosecution also introduced evidence that Holmes had been seen near the victim's home within an hour of when the prosecutor believed the attack took place.
As a major part of his defense, Holmes presented expert witnesses who claimed that the forensic evidence was contaminated by poor handling procedures, and that the palm print was planted by police who Holmes asserted were trying to frame him. Holmes also tried to introduce proof that another man, Jimmy McCaw White, had actually attacked the victim. At a pretrial hearing, Holmes had presented several witnesses who placed White in the victim's neighborhood on the morning of the attack, and four other witnesses who testified that White had admitted to committing the crime, or at least acknowledged that Holmes was innocent. White testified at the pretrial hearing and denied making the incriminating statements. He also provided an alibi for the time of the crime, but this was refuted by another witness.
The trial court excluded Holmes' third-party guilt evidence based on ''State v. Gregory'', 16 S.E.2d 532 (S.C. 1941), in which the South Carolina Supreme Court had held that such evidence is only admissible if it "raises a reasonable inference or presumption as to (defendant's ) own innocence." Holmes was subsequently convicted again. On appeal, the South Carolina Supreme Court affirmed the conviction,〔''State v. Holmes'', 605 S.E. 2d 19 (S.C. 2004).〕 citing to both ''Gregory'' and its later decision in ''State v. Gay'' 541 S.E.2d 541 (S.C. 2001). The State Supreme Court held that "where there is strong evidence of an appellant's guilt, especially where there is strong forensic evidence, the proffered evidence about a third party's alleged guilt does not raise a reasonable inference as to the appellant's own innocence."〔''Id.'' at 24.〕 Applying this standard, the court held that petitioner could not "overcome the forensic evidence against him to raise a reasonable inference of his own innocence." The U.S. Supreme Court granted certiorari.〔''Holmes v. South Carolina'', 545 U.S. ___, 126 S. Ct. 34 (2005).〕

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