Law School Case Brief
People v. Hall - 41 CAL. 3D 826, 226 CAL. RPTR. 112, 718 P.2D 99 (1986)
To be admissible, the third-party evidence need not show substantial proof of a probability that the third person committed the act; it need only be capable of raising a reasonable doubt of defendant's guilt. At the same time, the courts do not require that any evidence, however remote, must be admitted to show a third party's possible culpability. Evidence of mere motive or opportunity to commit the crime in another person, without more, will not suffice to raise a reasonable doubt about a defendant's guilt: there must be direct or circumstantial evidence linking the third person to the actual perpetration of the crime.
Defendant Henry Loren Hall was convicted of murder. During the trial, defendant attempted to introduce evidence regarding two other persons who defendant argued were guilty of the murder with which defendant was being charged. Although defendant was able to introduce a great deal of evidence of the alleged guilt of the other parties, the trial court excluded some evidence based on case law (i.e., Mendez-Arline rule based on People v. Mendez and People v. Arline) which had held that a defendant must make a preliminary showing of substantial evidence that another committed the crime before such evidence was introduced to the jury. Defendant appealed his conviction, arguing that he was improperly prohibited from introducing evidence which tended to show that another person was guilty of the murder. The appellate court affirmed. The Supreme Court of California granted review in this case to examine and clarify the so-called Mendez-Arline rule, which restricts the admission of defense evidence tending to show that a third party is guilty of the offense charged.
In a criminal trial, did the trial court err when it applied the California Mendez-Arline Exclusionary Rule and required defendant to make a preliminary showing of "substantial probability" that the third party actually committed the crime?
The Supreme Court of California affirmed the judgment. Defendant contended that the trial court denied him the right to present more than a minimal defense founded on evidence that came in "through the back door," and that the trial court's reliance on Arline was error. The Court agreed, explaining that what has come to be called the Mendez-Arline test is an exclusionary rule abstracted from case law articulating the minimum threshold for admitting evidence of third-party culpability that tends to exonerate a defendant. Simply expressed, it provides that such evidence is admissible only if it constitutes "substantial evidence tending to directly connect that person with the actual commission of the offense." In this case, the Court held that it was error to require a preliminary showing of substantial evidence before evidence that another committed the crime could be introduced. However, defendant was able to introduce most of the evidence. Importantly, the evidence which he did not get in was not sufficient to have affected the outcome; hence, his conviction was still upheld.
On the basis of Arline, the trial court erred when it concluded that defendant was required to make a preliminary showing of "substantial probability" that the third party actually committed the crime. Instead, courts should simply treat third-party culpability evidence like any other evidence: if relevant it is admissible unless its probative value is substantially outweighed by the risk of undue delay, prejudice, or confusion. Accordingly, the Court rejected Arline to the extent that it creates a distinct and elevated standard for admitting this kind of exculpatory evidence.
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