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Regardless of whether testimony proffered by a defendant comes within a state's hearsay rule, the exclusion of such evidence constitutes a violation of the Due Process Clause of the Fourteenth Amendment where the excluded testimony is highly relevant to a critical issue in the punishment phase of the trial and substantial reasons existed to assume its reliability.
Two state criminal defendants were jointly indicted, tried separately, and convicted of murdering the same person. At his second trial, held for the purpose of deciding whether capital punishment should be imposed, one of the defendants sought to introduce certain testimony which indicated he was not present when the murder was committed, and therefore could not have participated directly in it. The testimony in question was that of a witness who had testified for the state at the trial of the second defendant, and who contended that the second defendant had admitted committing the murder out of the presence of the first defendant. The state trial court refused to allow introduction of the testimony, ruling that it was inadmissible hearsay under state law. The defendant received a capital sentence, and the Supreme Court of Georgia upheld the conviction and sentence. Certiorari was granted.
Under the circumstances, should the testimony of the witness have been allowed?
On review, the Court held that the exclusion of the proffered testimony denied petitioner of a fair trial regardless of whether the testimony came within the state's hearsay rule. The Court determined that the excluded testimony was highly relevant to a critical issue in the punishment phase of the trial and that substantial reasons existed to assume its reliability. The Court found that there was ample evidence corroborating the confession, that the statement was against interest, and that the State considered the evidence sufficiently reliable to use against the codefendant.