Abstract
The case of Holmes v. South Carolina, 547 U.S. 319 (2006) has been very significant in the state of South Carolina and the entire country particularly in the way DNA evidence overshadowed the third-party guilt evidence. In this paper, I will elaborate on the facts of the case, the main issues, and the court’s ruling and how it effected and affected the parties.
Facts of the case
The facts in the Holmes versus South Carolina case are as follows:
- Mary Stewart while at her home was beaten, robbed, and raped on the morning of 31st December 1989. The 86-year-old Mary Stewart later died from the injuries incurred during the incident.
- Bobby lee Holmes was sentenced to death after being convicted of murder, first-degree robbery and burglary, and first-degree criminal sexual conduct by a South Carolina jury.
- The prosecution relied on forensic evidence to convict the petitioner at the second trial. The following were the facts of the forensic evidence the prosecution heavily relied on (Gardner and Anderson, 2012).
- At the victim’s house, the palm print of Bobby Lee Holmes (petitioner) was found above the doorknob on the interior side of the front door.
- The underwear of one Bobby Lee Holmes, the petitioner in this case contained the DNA of two different individuals. As a result, the forensic evidence concluded that the two individuals were the victim and petitioner.
- Blue fibers found on the victim’s pink nightgown matched the petitioner’s blue jeans.
- The petitioner owned a black sweatshirt whose fibers were found on the victim’s bedsheets.
- A mixture of Bobby lee Holmes’s (petitioner) blood and that of the victim was found on the petitioner’s tank top.
- Prosecution introduced evidence that Bobby Lee Holmes (petitioner) had been seen near Mary Stewart’s residence within an hour before the crime was committed.
The issues before the Court
The issues that were brought before the court included the argument by the defense that the petitioner was framed and that the petitioner’s attempt to introduce evidence that another man, Jimmy McCaw White was the perpetrator of the crime.
In his Defense, the petitioner disputed the forensic evidence conducted by the state arguing that certain law enforcement officers had plotted to frame him, therefore the forensic evidence was contaminated.
One of the defense experts testified that the palm print above the doorknob on the interior side of the front door was planted by police as cited by the petitioner. On the other hand, the petitioner’s expert witness disagreed with the procedure used by law enforcement officers in capturing fingerprint evidence and also in the handling of DNA and fiber evidence.
In an attempt to introduce Jimmy McCaw White as the man responsible for the crimes the petitioner brought forward several witnesses who claimed to have seen Jimmy McCaw White in the victim’s neighborhood. The evidence confirmed that he was near the victim’s residence on the morning of the crime. In addition, four other witnesses testified that Jimmy McCaw White acknowledged that the petitioner was innocent and that he (White) was responsible for the crimes.
According to www.oppapers.com one of the major issues that ensued was the testimony by one witness that Jimmy McCaw White admitted that he committed the crimes and that he heard prosecutor’s office employees talk of how they manufactured evidence against the petitioner (2006). Also, the witness testified that the police officer had questioned him falsely against the petitioner.
Rule
Following the constitution of the United States, the court considered the defendant by allowing him to have a complete defense. Regarding the constitution, a defendant has a right to innocence until proven otherwise by a third party. In the Holmes case, the court did not have any right to make the ruling because it excluded the evidence and only heard the prosecutors’ evidence. The prosecution’s evidence concluded that the defendant was guilty but at the same time did not term the third party’s evidence as weak. As a result, Holmes had to present evidence declaring White’s guilt. Therefore, the court was at fault and violated Holmes’s right by denying him the chance to present his defense.
The court’s decision and rationale on the ruling given
The petitioner’s third-party guilt evidence citing was excluded by the court. The court ruled such evidence as admissible if it results in reasonable doubt or presumption as to the defendant’s innocence while it is not admissible if it is used to bring suspicion upon another. The court ruled out the third-party guilt evidence citing that it was also not admissible for it brought about interruption or doubt as to perpetration of crime by another. On appeal, the court maintained that it was not erroneous for it to exclude the petitioner’s third-party guilty evidence. The Supreme Court held that where there was strong evidence as produced by the forensics confirming the petitioner’s guilt, and also the evidence brought forward by the third party alleged guilt cannot bring reasonable interference on petitioner’s innocence (www.papers.ssrn.com, 2007)
Analysis
The standard relied on or established by court ruling on Holmes v. South Carolina, 547 U.S. 319 (2006) was the State versus Gregory case. In the State versus Gregory case, the court established that the evidence given by a third party can be admissible if it is found to “raise reasonable inference or presumption as to the defendant’s innocence” (Gardner and Anderson, 2012).
The court established a new standard on the admission of third-party guilt evidence citing especially when the petitioner is faced with strong and powerful forensic evidence against him. The standard was that in such circumstances the proof brought forward concerning the third party’s alleged guilt cannot result in a reasonable change on the petitioner’s innocence.
The significance of the Holmes versus South Carolina case
The most significant thing about the case is that although Jimmy McCaw white had admitted to committing the crime as per some witnesses’ testimonies, and also according to some witnesses the police framed the petitioner, all these could not interfere with the guilt of the petitioner in the face of overwhelming forensic evidence.
In conclusion, in the Holmes versus South Carolina case, justice Alito decided that the court violated the petitioner’s constitutional rights. Even though both federal and state rules makers have powers to limit evidence presented in cases, their powers cannot outweigh the clauses which guarantee defendants the right to provide complete defense during their trials (Broun, Mosteller, and Giannelli, 2007).
For this reason, the courts in the United States have been advised to always give criminal defendants the right to provide complete evidence on their defense.
References
Broun, K. S., Mosteller, R. P., & Giannelli, P. C. (2007). Evidence: Keyed to courses using Broun, Mosteller, and Giannelli’s Evidence: cases and materials, seventh edition. Austin: Wolters Kluwer Law & Business.
Gardner, T. J., & Anderson, T. M. (2012). Criminal law. Belmont, CA: Wadsworth Cengage Learning.
Holmes versus South Carolina 547 U.S. 319 (2006). Web.
Third-party culpability evidence 2007. Web.