Alexis Sutherland LSTD 503 Supreme Court Paper
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Holmes v. South Carolina
: Evidence Withheld
Alexis Sutherland
American Military University
LSTD503: Criminal Justice Process
Professor Michelle Young
December 18, 2022
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Holmes v. South Carolina
: Evidence Withheld
In 2006, the Supreme Court of the United States came across a case on its docket that was
argued at the end of February and decided only two short months later, on the first of May. This case was the case of Holmes v. South Carolina
, 547 U. S. 319 (2006) and, as the name suggests, legal action was brought against the state of South Carolina by a man named Bobby Lee Holmes.
Bobby Lee Holmes was initially brought into the criminal justice system through accusations and, eventually, the conviction of guilt to the murder of Mary Stewart in 1989 (Holmes V. South Carolina, 2008). Throughout the court proceedings, Bobby Lee Holmes had continuously attempted to present the court with evidence that he was innocent. However, the courts had continuously denied the attempts to introduce such evidence stating that it was a state rule that had barred (Holmes V. South Carolina, 2008) the evidence from being brought in because there was a significant amount of evidence proving guilt that was brought forth by the prosecution. The rule that was used as the basis for the decision preventing the admission to Mr. Holmes’ evidence was a law stating that only evidence that provide facts that reasonably infer (Holmes v. South Carolina, n.d.) innocence of the party may be admitted. Anything that simply raises suspicion to another party but does not provide facts supporting the accused’s innocence is
not allowed (Holmes v. South Carolina, n.d.). As a result of this, Bobby Lee Holmes was found guilty twice and sentenced to death both times. After his second conviction, Bobby Lee Holmes had appealed the trial court’s decision through the South Carolina Supreme Court. However, the South Carolina Supreme Court had upheld the trial court’s decision and Bobby Lee Holmes was unsuccessful in his appeal. This is where the question had come forth of whether or not Bobby Lee Holmes was denied his
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Constitutional rights, violating specifically his Sixth Amendment and Fourteenth Amendment rights of confrontation and compulsory process and the right to due process (Holmes v. South Carolina, n.d.). The next step was to take the case to the Supreme Court of the United States and
that is just what Bobby Lee Holmes did.
When his case had reached the Supreme Court of the United States, Bobby Lee Holmes was able to present his side, explaining that he had felt his rights had been violated by both the trial court both times he had dealt with it and the South Carolina Supreme Court. The Supreme Court Justices had all agreed and unanimously decided that the decision of the South Carolina Supreme Court was to be reversed. As such, Bobby Lee Holmes was able to get his new trial and finally be able to present the evidence that he had been trying for years to introduce into his case to prove his innocence to the courts in order to gain his freedom.
Going deeper into the decision of the Supreme Court of the United States and what the Justices had come to the conclusion about together to make the ruling unanimously is the rule or South Carolina state law that had been mentioned previously as the reason that was provided as to why Bobby Lee Holmes was unable to present his evidence in court. As mentioned above, the
law states that new evidence from the accused may only be presented if it contains facts of innocence and does not just place suspicion on someone else. This means that the strength of the
prosecutions case and evidence does not deny the accused their right to present their own evidence. This was the conclusion that the Supreme Court Justices had agreed to. In the statement made by Justice Samuel Alito in Holmes v. South Carolina
, 547 U. S. 319 (2006), withholding of
the evidence denies the defendant his constitutional right to “a meaningful opportunity to present
a complete defense” (Holmes v. South Carolina, n.d.) and leads to other influences that could
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interfere with the jury’s judgement, prejudice, and confusion that violate the defendant’s constitutional rights even more.
This ruling sets the precedent for future legal proceedings ensuring that defendants are not denied their rights to due process or any related constitutional rights by enforcing the allowance of defendants to present evidence that may prove their innocence when accused of committing a crime. This case also clears up the interpretation of South Carolina’s laws pertaining to when the evidence brought into question by a defendant can or cannot be excluded from the court proceedings.
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References
Holmes V. South Carolina. (2008). In L. J. Palmer,
Encyclopedia of capital punishment in the United States
(2nd ed.). McFarland. Credo Reference: https://search-credoreference-
com.ezproxy2.apus.edu/content/entry/mcfcpus/holmes_v_south_carolina/0
Holmes v. South Carolina. (n.d.). Oyez. Retrieved December 18, 2022, from https://www.oyez.org/cases/2005/04-1327