House v. Bell
Encyclopedia
House v. Bell, 547 U.S. 518
(2006), was a United States Supreme Court
case challenging the permissibility of new DNA
forensic
evidence that becomes available post-conviction, in capital punishment
appeal
s when those claims have defaulted
pursuant to state law. The Court found that admitting new DNA evidence was in line with a 1995 case, Schlup v. Delo
which allows cases to be reopened in light of new evidence.
ed to death in Luttrell, Tennessee
, near Knoxville
. Her body was found on an embankment the following day. Paul Gregory House, who was a friend of the Munceys, was charged with the murder. House was on parole
and had a prior aggravated sexual assault
conviction in Utah
Based on circumstantial evidence
that House was spotted near the embankment, that blood consistent with that of the victim was found on House's jeans, and that semen consistent with House's was found on the victim's nightgown and underwear, House was found guilty at trial with aggravating factors that qualified him for capital punishment
.
The Tennessee Supreme Court
affirmed House's conviction and sentence, describing the evidence against House as "circumstantial" but "quite strong." Later, in a state trial court, House filed a pro se petition for post-conviction relief, arguing that he received ineffective assistance of counsel
at trial and objecting to certain jury instructions
. At a hearing before the same judge who conducted the trial, the court dismissed the petition, deeming House's trial counsel adequate and overruling House's other objections. On appeal House's attorney renewed only the jury-instructions argument and the Tennessee Court of Criminal Appeals
affirmed, and both the Tennessee Supreme Court and the Supreme Court of the United States
denied review.
House filed a second post-conviction petition in state court reasserting his ineffective-assistance claim. After extensive litigation regarding whether House's claims were procedurally defaulted
, the Tennessee Supreme Court held that House's claims were barred under a state statute providing that claims not raised in prior post-conviction proceedings are presumptively waived.
House next sought federal habeas corpus
relief, asserting numerous claims of ineffective assistance of counsel and prosecutorial misconduct.
In November 2002, the United States Court of Appeals for the Sixth Circuit
reviewed the case in light of new DNA evidence that might exonerate House. The DNA taken from semen
on the victim's clothing matched her husband, and not House. Additionally, House advanced the theory that the blood found on his jeans was spilled onto them from autopsy samples while the evidence was being transported from Tennessee to the FBI crime lab. Two witnesses also came forward to say that the victim's husband, Hubert Muncey, had confessed
to the murder. In light of the new evidence, the Court of Appeals referred the case to the Tennessee Supreme Court, asking it to consider how the state law barring consideration of claims not raised in prior post-conviction appeals applies in this situation.
In December 2003, the Tennessee Supreme Court refused to consider whether new DNA evidence presented during death penalty appeals necessitates a new trial
, and declined to answer other questions posed. The Tennessee Supreme Court sent the case back to the Federal Court of Appeals. The Federal Court of Appeals narrowly rejected House's appeal
on October 6, 2004, in a 8-7 decision with strongly worded opinions from the dissenting judges.
On June 28, 2005, the U.S. Supreme Court
agreed to take up the case, to reconsider under what circumstances death penalty cases could be reopened in light of new evidence.
under state law may not be granted federal habeas corpus
review unless the petitioner provides a sufficient explanation for the default and demonstrates that the asserted error prejudiced his or her trial (that is, the error caused a different outcome). This standard, based on the principle of respect for state court judgments, is normally a difficult one for convicted defendants to meet.
The United States Supreme Court recognized a "miscarriage of justice" exception to the above rule for "extraordinary cases" in a 1995 decision, Schlup v. Delo
, 513 U.S. 298. That decision held that prisoners asserting innocence as a gateway to federal review of defaulted claims must establish that, in light of new evidence, "it is more likely than not that no reasonable juror would have found petitioner guilty beyond a reasonable doubt."
In House v. Bell, the Supreme Court found that House’s arguments based on new DNA and other evidence were sufficient to meet the Schlup standard.
Expert witnesses testified that Mrs. Muncey's blood samples taken during the autopsy were kept in test tubes without preservation and that in such conditions certain enzymes invariably degrade. The matching blood found on House's pants showed similar enzyme decay, in a way that would not have occurred if the victim's blood had come into contact with House's pants while she was still alive.
Other evidence supported this theory. During the investigation of Mrs. Muncey's murder, the doctor who performed the autopsy passed the vials to two local law enforcement officers who transported it to the FBI where further testing occurred. The blood was contained in four vials, evidently with neither preservative nor a proper seal. The vials, in turn, were stored in a foam box, but nothing indicates the box was kept cool. Rather, in violation of proper procedure, the foam box was packed in the same cardboard box as other evidence including House's pants and other clothing. The cardboard box was then carried in the officers' car while they made the 10-hour journey from Tennessee to the FBI lab. Blood vials in hot conditions (such as a car trunk in the summer) can blow open; and in fact, by the time the blood reached the FBI it had hemolyzed, or spoiled, due to heat exposure. By the time the blood passed from the FBI to a defense expert, roughly a vial and a half were empty, though the agent who had analyzed it testified he used at most a quarter of one vial. Blood, moreover, had seeped onto one corner of the foam box and onto packing gauze inside the box below the vials.
The Supreme Court declared that the bloodstains, as emphasized by the prosecution, seemed strong evidence of House's guilt at trial, but that new evidence raised substantial questions about the blood's origin.
The Supreme Court found this evidence "troubling" but did not decide that it was conclusive. "If considered in isolation, a reasonable jury might well disregard" such testimony, the Court stated. "In combination, however, with the challenges to the blood evidence and the lack of motive with respect to House, the evidence pointing to Mr. Muncey likely would reinforce other doubts as to House's guilt."
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case challenging the permissibility of new DNA
DNA
Deoxyribonucleic acid is a nucleic acid that contains the genetic instructions used in the development and functioning of all known living organisms . The DNA segments that carry this genetic information are called genes, but other DNA sequences have structural purposes, or are involved in...
forensic
Forensics
Forensic science is the application of a broad spectrum of sciences to answer questions of interest to a legal system. This may be in relation to a crime or a civil action...
evidence that becomes available post-conviction, in capital punishment
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
appeal
Appeal
An appeal is a petition for review of a case that has been decided by a court of law. The petition is made to a higher court for the purpose of overturning the lower court's decision....
s when those claims have defaulted
Default (law)
In law, a default is the failure to do something required by law or to appearat a required time in legal proceedings.In the United States, for example, when a party has failed to file meaningful response to pleadings within...
pursuant to state law. The Court found that admitting new DNA evidence was in line with a 1995 case, Schlup v. Delo
Schlup v. Delo
Schlup v. Delo, 513 U.S. 298 , was a case in which the United States Supreme Court expanded the ability to reopen a case in light of new evidence of innocence.Petitioner Lloyd E...
which allows cases to be reopened in light of new evidence.
Background and Procedural History
In 1985, Carolyn Muncey was bludgeonBludgeon
Bludgeon may refer to:* Bludgeon , a fictional character* Bludgeon , a club-like weapon* Crabtree's Bludgeon, a foil to Occam's Razor...
ed to death in Luttrell, Tennessee
Luttrell, Tennessee
Luttrell is a city in Union County, Tennessee, United States, with a population of 915 as of the 2000 census. It is included in the Knoxville, Tennessee Metropolitan Statistical Area.-History:...
, near Knoxville
Knoxville, Tennessee
Founded in 1786, Knoxville is the third-largest city in the U.S. state of Tennessee, U.S.A., behind Memphis and Nashville, and is the county seat of Knox County. It is the largest city in East Tennessee, and the second-largest city in the Appalachia region...
. Her body was found on an embankment the following day. Paul Gregory House, who was a friend of the Munceys, was charged with the murder. House was on parole
Parole
Parole may have different meanings depending on the field and judiciary system. All of the meanings originated from the French parole . Following its use in late-resurrected Anglo-French chivalric practice, the term became associated with the release of prisoners based on prisoners giving their...
and had a prior aggravated sexual assault
Sexual assault
Sexual assault is an assault of a sexual nature on another person, or any sexual act committed without consent. Although sexual assaults most frequently are by a man on a woman, it may involve any combination of two or more men, women and children....
conviction in Utah
Utah
Utah is a state in the Western United States. It was the 45th state to join the Union, on January 4, 1896. Approximately 80% of Utah's 2,763,885 people live along the Wasatch Front, centering on Salt Lake City. This leaves vast expanses of the state nearly uninhabited, making the population the...
Based on circumstantial evidence
Circumstantial evidence
Circumstantial evidence is evidence in which an inference is required to connect it to a conclusion of fact, like a fingerprint at the scene of a crime...
that House was spotted near the embankment, that blood consistent with that of the victim was found on House's jeans, and that semen consistent with House's was found on the victim's nightgown and underwear, House was found guilty at trial with aggravating factors that qualified him for capital punishment
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
.
The Tennessee Supreme Court
Tennessee Supreme Court
The Tennessee Supreme Court is the state supreme court of the state of Tennessee. Cornelia Clark is the current Chief Justice.Unlike other states, in which the state attorney general is directly elected or appointed by the governor or state legislature, the Tennessee Supreme Court appoints the...
affirmed House's conviction and sentence, describing the evidence against House as "circumstantial" but "quite strong." Later, in a state trial court, House filed a pro se petition for post-conviction relief, arguing that he received ineffective assistance of counsel
Ineffective assistance of counsel
Ineffective assistance of counsel is an issue raised in legal malpractice suits and in appeals in criminal cases where a criminal defendant asserts that their criminal conviction occurred because their attorney failed to properly defend the case...
at trial and objecting to certain jury instructions
Jury instructions
Jury instructions are the set of legal rules that jurors should follow when the jury is deciding a civil or criminal case. Jury instructions are given to the jury by the jury instructor, who usually reads them aloud to the jury...
. At a hearing before the same judge who conducted the trial, the court dismissed the petition, deeming House's trial counsel adequate and overruling House's other objections. On appeal House's attorney renewed only the jury-instructions argument and the Tennessee Court of Criminal Appeals
Tennessee Court of Criminal Appeals
The Court of Criminal Appeals is one of Tennessee's two intermediate appellate courts. It hears trial court appeals in felony and misdemeanor cases, as well as post-conviction petitions. Appeals in civil cases are heard by the Tennessee Court of Appeals....
affirmed, and both the Tennessee Supreme Court and the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
denied review.
House filed a second post-conviction petition in state court reasserting his ineffective-assistance claim. After extensive litigation regarding whether House's claims were procedurally defaulted
Default (law)
In law, a default is the failure to do something required by law or to appearat a required time in legal proceedings.In the United States, for example, when a party has failed to file meaningful response to pleadings within...
, the Tennessee Supreme Court held that House's claims were barred under a state statute providing that claims not raised in prior post-conviction proceedings are presumptively waived.
House next sought federal habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
relief, asserting numerous claims of ineffective assistance of counsel and prosecutorial misconduct.
In November 2002, the United States Court of Appeals for the Sixth Circuit
United States Court of Appeals for the Sixth Circuit
The United States Court of Appeals for the Sixth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Kentucky* Western District of Kentucky...
reviewed the case in light of new DNA evidence that might exonerate House. The DNA taken from semen
Semen
Semen is an organic fluid, also known as seminal fluid, that may contain spermatozoa. It is secreted by the gonads and other sexual organs of male or hermaphroditic animals and can fertilize female ova...
on the victim's clothing matched her husband, and not House. Additionally, House advanced the theory that the blood found on his jeans was spilled onto them from autopsy samples while the evidence was being transported from Tennessee to the FBI crime lab. Two witnesses also came forward to say that the victim's husband, Hubert Muncey, had confessed
Confession
This article is for the religious practice of confessing one's sins.Confession is the acknowledgment of sin or wrongs...
to the murder. In light of the new evidence, the Court of Appeals referred the case to the Tennessee Supreme Court, asking it to consider how the state law barring consideration of claims not raised in prior post-conviction appeals applies in this situation.
In December 2003, the Tennessee Supreme Court refused to consider whether new DNA evidence presented during death penalty appeals necessitates a new trial
Trial
A trial is, in the most general sense, a test, usually a test to see whether something does or does not meet a given standard.It may refer to:*Trial , the presentation of information in a formal setting, usually a court...
, and declined to answer other questions posed. The Tennessee Supreme Court sent the case back to the Federal Court of Appeals. The Federal Court of Appeals narrowly rejected House's appeal
Appeal
An appeal is a petition for review of a case that has been decided by a court of law. The petition is made to a higher court for the purpose of overturning the lower court's decision....
on October 6, 2004, in a 8-7 decision with strongly worded opinions from the dissenting judges.
On June 28, 2005, the U.S. Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
agreed to take up the case, to reconsider under what circumstances death penalty cases could be reopened in light of new evidence.
Supreme Court Decision
Generally, claims that have defaultedDefault (law)
In law, a default is the failure to do something required by law or to appearat a required time in legal proceedings.In the United States, for example, when a party has failed to file meaningful response to pleadings within...
under state law may not be granted federal habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
review unless the petitioner provides a sufficient explanation for the default and demonstrates that the asserted error prejudiced his or her trial (that is, the error caused a different outcome). This standard, based on the principle of respect for state court judgments, is normally a difficult one for convicted defendants to meet.
The United States Supreme Court recognized a "miscarriage of justice" exception to the above rule for "extraordinary cases" in a 1995 decision, Schlup v. Delo
Schlup v. Delo
Schlup v. Delo, 513 U.S. 298 , was a case in which the United States Supreme Court expanded the ability to reopen a case in light of new evidence of innocence.Petitioner Lloyd E...
, 513 U.S. 298. That decision held that prisoners asserting innocence as a gateway to federal review of defaulted claims must establish that, in light of new evidence, "it is more likely than not that no reasonable juror would have found petitioner guilty beyond a reasonable doubt."
In House v. Bell, the Supreme Court found that House’s arguments based on new DNA and other evidence were sufficient to meet the Schlup standard.
DNA Evidence
DNA tests established that the semen on Mrs. Muncey's nightgown and underwear came from her husband, Mr. Muncey, not from House. The State argued that since neither sexual contact nor motive were elements of the offense, this evidence would have not affected the jury’s decision to convict House had it been available at trial. The Supreme Court disagreed, stating that the new DNA evidence was of "central importance." A jury informed that fluids on Mrs. Muncey's garments could have come from House might have found that House traveled to the victim's home and lured her away in order to commit a sexual offense. According to the Court, a jury acting without the assumption that the semen could have come from House would have found it necessary to establish a different motive.Bloodstains
The other relevant forensic evidence in House’s trial was Mrs. Muncey's blood found on House's pants. House's attorneys argued that his pants were contaminated with samples of blood taken during Mrs. Muncey's autopsy.Expert witnesses testified that Mrs. Muncey's blood samples taken during the autopsy were kept in test tubes without preservation and that in such conditions certain enzymes invariably degrade. The matching blood found on House's pants showed similar enzyme decay, in a way that would not have occurred if the victim's blood had come into contact with House's pants while she was still alive.
Other evidence supported this theory. During the investigation of Mrs. Muncey's murder, the doctor who performed the autopsy passed the vials to two local law enforcement officers who transported it to the FBI where further testing occurred. The blood was contained in four vials, evidently with neither preservative nor a proper seal. The vials, in turn, were stored in a foam box, but nothing indicates the box was kept cool. Rather, in violation of proper procedure, the foam box was packed in the same cardboard box as other evidence including House's pants and other clothing. The cardboard box was then carried in the officers' car while they made the 10-hour journey from Tennessee to the FBI lab. Blood vials in hot conditions (such as a car trunk in the summer) can blow open; and in fact, by the time the blood reached the FBI it had hemolyzed, or spoiled, due to heat exposure. By the time the blood passed from the FBI to a defense expert, roughly a vial and a half were empty, though the agent who had analyzed it testified he used at most a quarter of one vial. Blood, moreover, had seeped onto one corner of the foam box and onto packing gauze inside the box below the vials.
The Supreme Court declared that the bloodstains, as emphasized by the prosecution, seemed strong evidence of House's guilt at trial, but that new evidence raised substantial questions about the blood's origin.
A Different Suspect
In the post-trial proceedings House's attorneys presented evidence that Mr. Muncey, the victim's husband, himself could have been the murderer. House's attorneys produced evidence from multiple sources suggesting that Mr. Muncey regularly abused his wife. Moreover, two witnesses at House's habeas hearing testified that, around the time of House's trial, Mr. Muncey had confessed to the crime. One witness recalled that she and "some family members and some friends [were] sitting around drinking" at her trailer when Mr. Muncey "just walked in and sit down." Muncey, who had evidently been drinking heavily, began "rambling off . . . talking about what happened to his wife and how it happened and he didn't mean to do it." According to the witness, Mr. Muncey "said [he and Mrs. Muncey] had been into [an] argument and he slapped her and she fell and hit her head and it killed her and he didn't mean for it to happen." The witness then said she "freaked out and run him off."The Supreme Court found this evidence "troubling" but did not decide that it was conclusive. "If considered in isolation, a reasonable jury might well disregard" such testimony, the Court stated. "In combination, however, with the challenges to the blood evidence and the lack of motive with respect to House, the evidence pointing to Mr. Muncey likely would reinforce other doubts as to House's guilt."
Holding
Though the Supreme Court did not find that House was conclusively exonerated, it concluded that had the jury heard all the conflicting testimony it is more likely than not that the reasonable juror would not be convinced of House's guilt beyond a reasonable doubt. Accordingly, House met the threshold standard set forth in Schlup and his case was remanded for consideration of the constitutional claims that had defaulted due to state law.On remand
On remand, House's petition for relief was granted. He was released from prison several months later. The prosecutor originally said he would retry House, but eventually dropped the charges.See also
External links
- Opinion of the Supreme Court of the United States
- Opinion of the Federal Court of Appeals - Decided on October 6, 2004.
- A lengthy study of the House case