House v. Bell
Supreme Court of the United States
January 11, 2006, Argued ; June 12, 2006, Decided
[*521] [**2068] Justice Kennedy delivered the opinion of the Court.
LEdHN[1A] [1A] LEdHN  Some 20 years ago in rural Tennessee, Carolyn Muncey was murdered. A jury convicted petitioner [***12] Paul Gregory House of the crime and sentenced him to death, but new revelations cast doubt on the jury's verdict. House, protesting his innocence, seeks access to federal court to pursue [*522] habeas corpus relief based on constitutional claims that are procedurally barred under state law. HN1 Out of respect for the [****9] finality of state-court judgments federal habeas courts, as a general rule, are closed to claims that state courts would consider defaulted. In certain exceptional cases involving a compelling claim of actual innocence, however, the state procedural default rule is not a bar to a federal habeas corpus petition. See Schlup v. Delo, 513 U.S. 298, 319-322, 115 S. Ct. 851, 130 L. Ed. 2d 808 (1995). After careful review of the full record, we conclude that House has made the stringent showing required by this exception; and we hold that his federal habeas action may proceed.
We begin with the facts surrounding Mrs. Muncey's disappearance, the discovery of her body, and House's arrest. Around 3 pm. on Sunday, July 14, 1985, two local residents found her body concealed amid brush and tree branches on an embankment roughly 100 yards up the road from her driveway. Mrs. Muncey had been seen last on the evening before, when, around 8 pm., she and her two children--Lora Muncey, aged 10, and Matthew Muncey, aged 8--visited their neighbor, Pam Luttrell. According to Luttrell, Mrs. Muncey mentioned her husband, William Hubert Muncey, Jr., known in the community as "Little Hube" and to his family as "Bubbie. [****10] " As Luttrell recounted Mrs. Muncey's comment, Mr. Muncey [**2069] "had gone to dig a grave, and he hadn't come back, but that was all right, because [Mrs. Muncey] was going to make him take her fishing the next day," App. 11-12. Mrs. Muncey returned home, and some time later, before 11 p.m. at the latest, Luttrell "heard a car rev its motor as it went down the road," something Mr. Muncey customarily did when he drove by on his way home. Record, Addendum 4, 5 Tr. of Evidence in No. 378 (Crim. Ct. Union County, Tenn.), pp. 641-642 (hereinafter Tr.). Luttrell then went to bed.
Around 1 a.m., Lora and Matthew returned to Luttrell's home, this time with their father, Mr. Muncey, who said his [*523] wife was missing. Muncey asked Luttrell to watch the children while he searched for his wife. After he left, Luttrell talked with Lora. According to Luttrell: Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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547 U.S. 518 *; 126 S. Ct. 2064 **; 165 L. Ed. 2d 1 ***; 2006 U.S. LEXIS 4675 ****; 74 U.S.L.W. 4291; 23 A.L.R. Fed. 2d 633; 19 Fla. L. Weekly Fed. S 229
PAUL GREGORY HOUSE, Petitioner v. RICKY BELL, WARDEN
Subsequent History: [****1] On remand at Paul Gregory House v. Bell, 466 F.3d 549, 2006 U.S. App. LEXIS 26429 (6th Cir.) (6th Cir., 2006)
Prior History: ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT.
House v. Bell, 386 F.3d 668, 2004 U.S. App. LEXIS 20915 (6th Cir. Tenn., 2004)
Disposition: Reversed and remanded.
blood, district court, pants, motive, murder, reliability, stains, night, semen, new evidence, testing, credibility, box, clothing, innocence, spillage, bloodstains, autopsy, spilled, enzyme, inside, questions, evidentiary hearing, reasonable juror, guilt, actual innocence, container, killed, defaulted, evening
Criminal Law & Procedure, Exceptions to Default, Actual Innocence & Miscarriage of Justice, Exceptions, Miscarriage of Justice, Proof of Innocence, Habeas Corpus, Evidentiary Hearings, General Overview, Review, Standards of Review, Deference