Defendant's Right To Present Evidence Without Judicial Interference

• Jurisdiction: Maryland

III. Defendant's right to present evidence without judicial interference

A. Right to present evidence of actual innocence and/or evidence of third-party guilt

The defendant may present evidence to refute the State's case and/or to present evidence to provide a defense. In Holmes v. South Carolina, 547 U.S. 319 (2006), the Supreme Court held that the Compulsory Process Clause entitles the defendant to present evidence of actual innocence by producing evidence of the guilt of a third party.

In Holmes, the State presented a strong prima facie case of rape and robbery. The defendant argued that police framed him and wanted to introduce evidence of a third party's guilt, which the trial court denied. The Supreme Court held that the defendant's constitutional right to present a meaningful defense was violated, stating: "[B]y evaluating the strength of only one party's evidence, no logical conclusion can be reached...