A defendant has a constitutional right to present a complete defense, including the right to introduce evidence of third-party guilt. In this case, defense counsel’s trial strategy was to advance an effective and credible third-party-guilt defense that Thomas — not Hannah — committed the crime. The success of that trial strategy required counsel merely to raise a reasonable doubt about Hannah’s guilt. Third-party-guilt evidence is admissible so long as the proof offered has a rational tendency to engender a reasonable doubt with respect to an essential feature of the State’s case, and third-party statements against penal interest are generally admissible where the proffered evidence draws a direct connection between the third party and the commission of the crime.
Hannah was both fortunate to have belatedly received his entire case file and to have had a PCR attorney that thoroughly reviewed a voluminous and complicated record. But for the loss of the first file during a prison lockdown, he would have never been privy to the Redd report. But for his fourth PCR attorney’s highlighting a key finding by the third PCR judge, he would not have had the ammunition required to convince a slim 4-3 majority of the Court to overturn his conviction and grant a new trial.