Holmes v. South Carolina

After Holmes (defendant) was convicted of murder, sexual assault, burglary, and robbery and later won a new trial on post-conviction review, he sought at the new trial to introduce evidence that another man, Jimmy McCaw White, had actually committed the crimes against the victim. The trial court excluded this third-party-guilt evidence, and the South Carolina Supreme Court affirmed the exclusion on the theory that such evidence is inadmissible whenever it merely implicates a third party without itself exculpating the defendant; the U.S. Supreme Court granted certiorari.