Amir Anariba v. California

The Constitution guarantees criminal defendants a meaningful opportunity to present a complete defense. This right is abridged by evidence rules that infringe on the weighty interest of the accused and are “arbitrary” or “disproportionate to the purposes they are designed to serve.” Holmes v. South Carolina, 547 U.S. 319, 324-325 (2006). In Holmes, this Court invalidated a state court rule that disallowed defense introduction of third-party culpability evidence where there was strong evidence of guilt against the accused. The rule was arbitrary because no logical conclusion can be reached regarding the strength of third-party culpability evidence based only on an evaluation of the strength of the prosecution’s evidence. Individuals accused of criminal offenses rely on the Sixth Amendment’s guarantee of compulsory process as an essential tool for investigation and trial preparation. “To ensure that justice is done, it is imperative to the function of courts that compulsory process be available for the production of evidence needed either by the prosecution or by the defense.” United States v. Nixon, 418 U.S. 683, 709 (1974). The question presented is: May a state court assume the truth of the prosecution’s evidence in deciding whether the accused has established a “plausible justification” in support of a subpoena duces tecum to overcome a motion to quash? (i)