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Consider the situation in which when I left my house in the morning for working, I found the street was wet. I think the following expression is ungrammatical.
昨日雨が降ったそうだ。
Because ～そうだ (conjecture) must represent event that will happen in the future or represent the current state of something or someone.
昨日雨が降りそうだった。
does not make sense as well, right?
So what is the correct expression to say the following?
There might be raining yesterday.
You can use ～ようだ that means "seeming to be" or "appearing to be":
昨日雨が降ったようだ。
It seems that it rained yesterday.
By the way, 昨日雨が降りそうだった。 is still a valid sentence which means "it seemed likely to rain yesterday."
This is valid because "雨が降りそう" was a conjecture about future or present at the time it was made.
