House v. Bell
547 U.S. 518 (2006)
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Rule of Law:
To overcome a state procedural default, a federal habeas petitioner asserting a gateway claim of actual innocence under Schlup v. Delo must present new, reliable evidence and demonstrate that, in light of all the evidence (old and new), it is more likely than not that no reasonable juror would have found the petitioner guilty beyond a reasonable doubt.
Facts:
- In July 1985, Carolyn Muncey was found murdered on an embankment near her rural Tennessee home.
- The night she disappeared, Muncey's daughter, Lora, heard a man with a deep voice tell her mother that her husband, William Hubert Muncey, Jr. ('Little Hube'), had been in a car wreck, luring her from the house.
- The next day, a witness, Billy Ray Hensley, saw Paul Gregory House emerge from the embankment near where Muncey's body was later discovered.
- When questioned, House had scratches on his arms and a bruised knuckle, and he provided a false alibi that he had been with his girlfriend, Donna Turner, all evening.
- Turner later told police that House had left her trailer for a period that night and returned panting, hot, and missing his shirt and shoes.
- At trial, the state presented forensic evidence that semen found on Muncey's nightgown was consistent with House's blood type and that bloodstains on House's jeans were consistent with Muncey's blood, but not his own.
Procedural Posture:
- Paul Gregory House was convicted of first-degree murder and sentenced to death in a Tennessee state trial court.
- The Tennessee Supreme Court affirmed his conviction and sentence on direct appeal.
- House's first state petition for postconviction relief, alleging ineffective assistance of counsel, was denied by the trial court, and the denial was affirmed by the Tennessee Court of Criminal Appeals.
- A second state postconviction petition was dismissed by Tennessee courts as procedurally barred for failing to raise claims in the prior proceeding.
- House then filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Tennessee, asserting his constitutional claims were procedurally defaulted.
- The District Court held an evidentiary hearing on House's 'actual innocence' claim but ultimately denied the petition.
- A divided en banc panel of the U.S. Court of Appeals for the Sixth Circuit affirmed the District Court's denial of habeas relief.
- The U.S. Supreme Court granted certiorari to determine whether House had satisfied the 'actual innocence' gateway standard.
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Issue:
Does a federal habeas petitioner satisfy the 'actual innocence' gateway standard of Schlup v. Delo by presenting new evidence that establishes the semen found on the victim belonged to her husband, raises substantial questions about the integrity of the blood evidence, and includes testimony that the victim's husband confessed to the murder?
Opinions:
Majority - Justice Kennedy
Yes, a petitioner satisfies the Schlup standard under these circumstances. To pass through the 'actual innocence' gateway, a petitioner must show that in light of new evidence, it is more likely than not that no reasonable juror would have convicted him. Here, House presented new evidence of central importance: DNA testing established that the semen on the victim's clothing belonged to her husband, not House, which undermined the prosecution’s theory of a sexual motive. Second, House introduced credible expert testimony suggesting the victim’s blood on his jeans could have resulted from spillage from poorly handled autopsy samples, casting serious doubt on the only other piece of forensic evidence linking him to the crime. Finally, new witnesses testified that the victim's husband had a history of domestic abuse and had confessed to the murder. While no single piece of new evidence is exonerating, the total effect of this evidence, when considered with the old, raises sufficient doubt about House's guilt to meet the demanding Schlup standard and allow his defaulted constitutional claims to be heard.
Concurring-in-part-and-dissenting-in-part - Chief Justice Roberts
No, the petitioner has not satisfied the demanding 'actual innocence' standard. The Schlup gateway requires a showing that no reasonable juror would have convicted, and the district court, which held an extensive evidentiary hearing, made reliability findings that should be respected. The district court found the new witnesses who claimed the victim's husband confessed were not credible, in part because they waited over a decade to come forward. The court also concluded that the blood spillage occurred after the FBI had already tested the jeans and found the victim's blood on them. The new DNA evidence regarding the semen is not dispositive because the prosecution's case did not hinge on a sexual motive. The original evidence of guilt—including House’s lies to police, his discredited alibi, his physical injuries, and his presence near the crime scene—remains powerful enough that a reasonable juror could still vote to convict.
Analysis:
This case clarifies the application of the Schlup v. Delo 'actual innocence' gateway, demonstrating that a petitioner can meet this high standard without presenting conclusive proof of innocence. The decision emphasizes a holistic review, where the combined effect of multiple pieces of new evidence—each casting doubt on a different aspect of the state's case—can be sufficient to undermine confidence in the original verdict. It establishes that successfully challenging the central forensic evidence and presenting a credible alternative suspect are powerful factors in the analysis. The case reinforces that the Schlup standard is a demanding but not impossible hurdle for petitioners with compelling new evidence.
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