Holmes v. South Carolina, 547 U.S. 319 (2006), was a decision by the United States Supreme Court involving the right of a criminal defendant to present evidence that a third party instead committed the crime.

After a four-day jury trial in York County Circuit Court in 1993, Bobby Lee Holmes was convicted of the crime and sentenced to death.

On appeal, the South Carolina Supreme Court affirmed the conviction,[7] citing to both Gregory and its later decision in State v. Gay 541 S.E.2d 541 (S.C. 2001).

Though state and federal rulemakers have broad constitutional latitude to establish rules of evidence in criminal trials, this is limited by the guarantee that criminal defendants have "a meaningful opportunity to present a complete defense", a right protected by both the Compulsory Process Clause of the Sixth Amendment and the Due Process Clause of the Fourteenth Amendment.

The Court noted that it had elaborated on this standard by permitting the exclusion of evidence that is "repetitive, only marginally relevant or poses an undue risk of harassment, prejudice, or confusion of the issues".

[14] However, the Court considered the later decision in State v. Gay and the instant case to represent a radical change and extension of the Gregory rule.

[16] This rule was in error, the Court wrote, because it required the trial judge to focus on the strength of the prosecution's case instead of the probative value or the potential adverse effects of admitting the defense evidence of third-party guilt.

The Court also believed that, as applied in this case, the rule did not seem to require any substantial examination of the credibility of the prosecution's witnesses or the reliability of its evidence.