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Holmes v. South Carolina

United States Supreme Court
547 U.S. 319 (2006)


Facts

Holmes (defendant) was charged with murder, sexual assault, burglary, and robbery in connection with an incident involving the victim, Mary Stewart, at her home. The trial court convicted Holmes, the South Carolina Supreme Court affirmed the conviction, and the United States Supreme Court denied certiorari. However, upon state post-conviction review, a new trial was ordered. At the new trial, Holmes sought to introduce proof that another man, Jimmy McCaw White, was actually the one who had committed the crimes against Stewart. The trial court excluded this evidence of third party guilt and the South Carolina Supreme Court affirmed on the grounds that evidence of a third party’s guilt is not admissible if it merely implicates a third party and does not exculpate the defendant. The United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Alito, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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