Holmes v. South Carolina

547 U.S 319 (2006)

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Nature of the Case

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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 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 ' 'casts a bare suspicion upon another' ' or ' 'raises 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.