Because Alito joined the Court mid-term, he did not participate in the decisions of most of the early cases in the Court term because he had not heard arguments for them. These decisions were released with an 8-member Court; none were 4–4, so Alito would not have been the deciding vote in any of them if he had participated. Only three of these cases – Garcetti v. Ceballos, Hudson v. Michigan, and Kansas v. Marsh – were reargued since a tie needed to be broken. U.S. Supreme Court Alito delivered his first written opinion on May 1, 2006, in Holmes v. South Carolina, a case involving the right of criminal defendants to present evidence that a third party committed the crime. From the beginning of the Rehnquist Court to the nomination of Justice Elena Kagan, new justices have been given unanimous opinions to write as their first opinion, often done as a courtesy "breaking in" of new justices, so that every justice has at least one unanimous, uncontroversial opinion under their belt. Alito wrote for a unanimous court in ordering a new trial for Bobby Lee Holmes due to South Carolina's rule that barred such evidence based on the strength of the prosecution's case, rather than on the relevance and strength of the defense evidence itself. His other majority opinions in his first term were in Zedner v. United States, Woodford v. Ngo, and Arlington Central School District Board of Education v. Murphy. In his first term, Alito voted fairly conservatively. For example, in the three reargued cases (Garcetti v. Ceballos, Hudson v. Michigan and Kansas v. Marsh), Alito created a 5–4 majority by voting with the four other conservative Justices – Chief Justice Roberts and Justices Scalia, Kennedy, and Thomas. He further voted with the conservative wing of the court on Sanchez-Llamas v. Oregon and Rapanos v. United States. Alito also dissented in Hamdan v. Rumsfeld, alongside Justices Scalia and Thomas. In 2013, Alito was considered "one of the most conservative justices on the Court". But while his voting record is conservative, he does not always join the other conservative justices on the Court. On February 1, 2006, in Alito's first decision on the Supreme Court, he voted with the majority (6–3) to refuse Missouri's request to vacate the stay of execution issued by the Eighth Circuit for death-row inmate Michael Taylor; Chief Justice Roberts and Justices Scalia and