House v. Bell

PETITIONER: Paul Gregory House
RESPONDENT: Ricky Bell, Warden
LOCATION: Board of Immigration Appeals

DOCKET NO.: 04-8990
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 547 US 518 (2006)
GRANTED: Jun 28, 2005
ARGUED: Jan 11, 2006
DECIDED: Jun 12, 2006

ADVOCATES:
Jennifer L. Smith - argued the cause for Respondent
Stephen M. Kissinger - argued the cause for Petitioner

Facts of the case

Paul House was sentenced to death for murder based on circumstantial evidence. House then submitted a habeas petition in federal court, claiming that he had new evidence demonstrating his innocence. The Sixth Circuit Court of Appeals denied his petition, finding he had failed to show that it was "more likely than not that no reasonable juror would have convicted him in the light of the new evidence," the standard of review established for habeas petitions in Schlup v. Delo. Even though the evidence cast some doubt on the original evidence, it was not sufficient to warrant a habeas petition.

Question

Did the federal appeals court err in applying Schlup v. Delo to hold that House's new evidence, though presenting at the very least an arguable claim of innocence, was legally insufficient to excuse his failure to present that evidence in state court? What constitutes a "truly persuasive showing of actual innocence" under Herrera v. Collins, sufficient to warrant freestanding habeas relief?

Media for House v. Bell

Audio Transcription for Oral Argument - January 11, 2006 in House v. Bell

Audio Transcription for Opinion Announcement - June 12, 2006 in House v. Bell

Anthony M. Kennedy:

The first case is the opinion of the Court in House versus Bell, No. 04-8990.

The petitioner, Paul Gregory House, was convicted of murder in a Tennessee state court and sentenced to death.

Now, some 20 years after the crime, he seeks access to federal court to pursue habeas-corpus relief, based on alleged Constitutional defects in his trial.

His claims are procedurally barred under Tennessee law.

As a general rule, that bar would prevent a federal habeas court from hearing them.

We have recognized an exception to that general rule.

The Court, in Schlup versus Delo, decided in 1995, held that in certain exceptional cases, a compelling claim of actual innocence may provide a gateway for federal habeas review, even if those claims are procedurally defaulted.

The standard set forth in Schlup requires that in light of new evidence not presented at trial, it is more likely than not that no reasonable juror would have found the petitioner guilty beyond a reasonable doubt.

House argues he falls within this exception.

The United States District Court for the Eastern District of Tennessee heard evidence regarding House's claim and held that he had not satisfied the Schlup standard.

The United States Court of Appeals for the 6th Circuit, sitting en banc, affirmed by a divided vote.

We now reverse.

The facts in the case are complex.

The trial and the habeas proceedings have left a lengthy record.

In brief, the evidence at trial pointing to petitioner House's guilt was as follows: first, tests found that semen bearing traces of House's blood types were on the victim's clothing.

In addition, blood consistent with the victim's was found in small stains on House's jeans. House, who was on parole at the time of the crime, falsely informed authorities that he had not left his girlfriend's home on the night of the crime.

In fact, he had left the home and had returned hot and short of breath, missing his shirt and shoes.

House was spotted the following day near where the victim's body was found just up the road from the victim's home; and the victim's daughter, then ten years old, recalled hearing a deep voice call out to her mother, the victim, on the night of the crime, and petitioner House has a deep voice.

Despite this evidence, three revelations lead us to conclude, although the issue is close, that more likely than not, no reasonable juror apprised of the full record would find House guilty beyond a reasonable doubt first.

DNA testing has established that the semen found on the victim could not have come from House; it came instead from the victim's husband.

The State points out that motive is not an element of the offense.

We think the evidence nevertheless is significant.

From beginning to end, the cases about who committed the crime, when identity is in question, motive is key.

While the evidence at trial suggested a sexual-assault motive for the crime, a jury acting without that assumption would find it necessary to establish some different motive or, if the same motive, an intent far more speculative.

The second consideration supporting reasonable doubt relates to the blood found on House's jeans.

Although House does not dispute at this stage that the blood is the victim's, he suggests it could have gotten on his jeans through spillage from blood samples collected during the victim's autopsy.

Although the jury did not learn of these facts, significant quantities of blood, in fact, spilled from the samples.

Now, the opinion discusses at great length the possible significance of this evidentiary disarray, and we conclude that the dispute likely would have prevented reasonable jurors from placing significant reliance on the blood evidence finally.

In the habeas proceedings, House presented troubling evidence that the victim's husband and not House could have been the murderer.

In particular, two witnesses testified that they heard the husband confess to the crime; another witness recalled witnessing a fight between the husband and the victim around the time of the crime; a fourth witness claimed the husband visited her the day after the crime and attempted to create a false alibi; and other witnesses described a history of domestic abuse.