House v. Bell
Issues
Under Schlup v. Delo and Herrera v. Collins, how much evidence must an individual present in order to prove his actual innocence to obtain habeas corpus relief and review of procedurally defaulted claims?
Carloyn Muncey was murdered on July 13, 1985 in Union County, Tennessee. Her badly beaten body was found the next day in a brush pile about one hundred yards from her house, and it appeared as though a strong blow to her head had killed her after a long struggle. That same day, two witnesses saw Paul House emerging from the area where Muncey’s body was discovered wiping his hands with a dark rag. Several witnesses, as well as House, gave conflicting statements as to where he was the night of the crime. Over the course of the investigation of the murder, FBI officials found blood on House’s jeans that they determined was Muncey’s blood, as well as semen on Muncey’s clothes that they determined was likely House’s. Based on this circumstantial evidence, a jury in Union County convicted House of first-degree murder and sentenced him to the death penalty based on three aggravating circumstances. During post-conviction relief proceedings in state and federal courts, House presented evidence that he was actually innocent of the crime. This new evidence included a confession from Muncey’s husband that he had murdered her, DNA evidence that it was not House’s semen on Muncey’s clothes, and evidence that the blood on his jeans was spilled onto his jeans after the autopsy on Muncey. None of the courts reviewing House’s case found his evidence sufficient to establish his actual innocence, however, and did not allow for review of his procedurally defaulted claims, such as ineffective assistance of counsel at trial, or to obtain relief from his conviction. The United States Supreme Court must now determine how much evidence an individual such as House must present to prove his actual innocence and overturn a jury’s conviction and death sentence, as well as how much evidence is necessary to establish House’s innocence so that a court can review his procedurally defaulted claims.
Questions as Framed for the Court by the Parties
1. Did the majority below err in applying this Court’s decision in Schlup v. Delo to hold that Petitioner’s compelling new evidence, though presenting at the very least a colorable claim of actual innocence, was as a matter of law insufficient to excuse his failure to present that evidence before the state courts – merely because he had failed to negate each and every item of circumstantial evidence that had been offered against him at the original trial?
2. What constitutes a “truly persuasive showing of actual innocence” pursuant to Herrera v. Collins sufficient to warrant freestanding habeas relief?
Additional Resources
- Wikipedia on habeas corpus.
- Transcript of an interview between a CNN correspondent and Paul House.
- More coverage of this case from truthinjustice.org.
- More on the AEDPA.