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Law School Case Brief

House v. Bell - 547 U.S. 518, 126 S. Ct. 2064 (2006)


With regard to a habeas claim of actual innocence, the standard is demanding and permits review only in the extraordinary case. At the same time, though, the standard does not require absolute certainty about a petitioner's guilt or innocence. The petitioner's burden at the gateway stage is to demonstrate that more likely than not, in light of the new evidence, no reasonable juror would find him guilty beyond a reasonable doubt—or, to remove the double negative, that more likely than not any reasonable juror would have reasonable doubt.


A Tennessee jury convicted Paul Gregory House of Carolyn Muncey's murder and sentenced him to death. The State's case included evidence that FBI testing showed semen consistent with House's on Mrs. Muncey's clothing and small bloodstains consistent with her blood, and inconsistent with House's blood, on his jeans. In the sentencing phase, the jury found the aggravating factor that the murder was committed while House was committing, attempting to commit, or fleeing from the commission of rape or kidnaping. In affirming, the State Supreme Court described the evidence as circumstantial but strong. House was denied state post-conviction relief. Subsequently, House applied for habeas relief, which the federal district court denied, deeming House's claims procedurally defaulted. The court granted the State summary judgment on most of his claims. At an evidentiary hearing, House attacked the blood and semen evidence and presented other evidence. He also gave a putative confession from the husband, Mr. Muncey, suggesting that he had committed the crime. The court, however, found that House did not fall within the "actual innocence" exception to procedural default recognized in Schlup v. Delo and Sawyer v. Whitley. The Sixth Circuit ultimately affirmed.


Did the federal district court err in its decision to deny House's petition for post-conviction relief?




The U.S. Supreme Court held that, while there was no showing of conclusive exoneration, consideration of House's claims was warranted despite procedural default since it was more likely than not that no reasonable juror viewing the record as a whole would lack reasonable doubt. According to the Court, although sexual assault was not an element of the offense, the semen evidence was used to infer the inmate's motive and to support the death penalty, and the only other forensic evidence, the bloodstains, was shown to be of questionable origin. Further, testimony that the husband confessed and evidence that the alcoholic husband regularly abused the victim potentially indicated the husband as the murderer. In light of this, the judgment upholding the denial of habeas corpus relief was reversed and the case was remanded for consideration of the inmate's procedurally barred claims.

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