House v. Bell | |
---|---|
![]() | |
Argued January 11, 2006 Decided June 12, 2006 | |
Full case name | Paul Gregory House, Petitioner v. Ricky Bell, Warden |
Docket no. | 04-8990 |
Citations | 547 U.S. 518 ( more ) 126 S. Ct. 2064; 165 L. Ed. 2d 1; 2006 U.S. LEXIS 4674 |
Case history | |
Prior | 311 F.3d 767 (6th Cir. 2002); cert. denied, 539 U.S. 937(2003); 386 F.3d 668 (6th Cir. 2004); cert. granted, 545 U.S. 1151(2005). |
Holding | |
Post-conviction DNA forensic evidence can be considered in death penalty appeals. | |
Court membership | |
| |
Case opinions | |
Majority | Kennedy, joined by Stevens, Souter, Ginsburg, Breyer |
Concur/dissent | Roberts, joined by Scalia, Thomas |
Alito took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. amend. IV |
House v. Bell, 547 U.S. 518 (2006), is a United States Supreme Court case challenging the permissibility of new DNA forensic evidence that becomes available post-conviction, in capital punishment appeals when those claims have defaulted pursuant to state law. [1] The Court found that admitting new DNA evidence was in line with Schlup v. Delo (1995), [2] which allows cases to be reopened in light of new evidence.
In 1985, Carolyn Muncey was bludgeoned 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. [3] 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. [4] 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. [5] Two witnesses 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. [6]
The Federal Court of Appeals narrowly rejected House's appeal on October 6, 2004, in an 8-7 decision with strongly worded opinions from the dissenting judges. [7] [8]
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. [9]
Generally, claims that have defaulted 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 . [2] 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." [2]
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 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 for her murder.
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. They said 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 carried in the officers' car, and transported 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. 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, was found to have 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 and its timing.
In the post-trial proceedings, House's attorneys presented evidence that Mr. Muncey, the victim's husband, could have been the murderer. House's attorneys produced evidence from multiple sources suggesting that Muncey regularly abused his wife. Moreover, two witnesses at House's habeas hearing testified that, around the time of House's trial, 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 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, 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."
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 House's case was remanded for consideration of the constitutional claims that had defaulted due to state law.
On remand to the Federal Court of Appeals, House's petition for relief was granted. [10] He was released from prison several months later in 2006 but returned due to procedural challenges from the state, and held for two more years. [11] The prosecutor originally said he would retry House and believed that he was involved in the murder, but finally dropped the charges in May 2009. He said that new, more refined DNA tests of forensic evidence pointed to an unknown perpetrator. [12] House spent over 22 years on Tennessee's death row before being released on bond in 2008. [13]
The West Memphis Three are three men convicted as teenagers in 1994 of the 1993 murders of three boys in West Memphis, Arkansas, United States. Damien Echols was sentenced to death, Jessie Misskelley Jr. to life imprisonment plus two 20-year sentences, and Jason Baldwin to life imprisonment. During the trial, the prosecution asserted that the juveniles killed the children as part of a Satanic ritual.
Kevin Cooper is an American man currently imprisoned at San Quentin State Prison's death row. Cooper was found guilty of four murders in the Chino Hills area of California in 1983. Cooper's conviction has garnered repeated attention from both Nicholas Kristof in the New York Times and Erin Moriarty on the CBS News program "48 Hours." There have been accusations that Cooper received an inadequate defense, as well as prosecutorial misconduct such as destruction of evidence, withholding exculpatory evidence from the defense, planting of evidence, brainwashing to witnesses, and perjured testimony by the Sheriff's Department. There have also been practical questions raised, such as how Cooper, at 155 pounds, and allegedly acting alone, overpowered a 6-foot, 2-inch ex-military policeman and his athletic wife, both of whom had loaded firearms close at hand. It has also been questioned why a single perpetrator would use 3 or 4 different weapons to commit the murders, and why none of the victims were able to run away while the others were being attacked.
Barry Charles Scheck is an American attorney and legal scholar. He received national media attention while serving on O. J. Simpson's defense team, collectively dubbed the "Dream Team", helping to win an acquittal in the highly publicized murder case. Scheck is the director of the Innocence Project and a professor at Yeshiva University's Benjamin N. Cardozo School of Law in New York City.
Steven Allan Avery is an American convicted murderer from Manitowoc County, Wisconsin, who had previously been wrongfully convicted in 1985 of sexual assault and attempted murder. After serving 18 years of a 32-year sentence, Avery was exonerated by DNA testing and released in 2003, only to be charged in another murder case two years later.
Actual innocence is a special standard of review in legal cases to prove that a charged defendant did not commit the crimes that they were accused of, which is often applied by appellate courts to prevent a miscarriage of justice.
False evidence, fabricated evidence, forged evidence, fake evidence or tainted evidence is information created or obtained illegally in order to sway the verdict in a court case. Falsified evidence could be created by either side in a case, or by someone sympathetic to either side. Misleading by suppressing evidence can also be considered a form of false evidence ; however, in some cases, suppressed evidence is excluded because it cannot be proved the accused was aware of the items found or of their location. The analysis of evidence may also be forged if the person doing the forensic work finds it easier to fabricate evidence and test results than to perform the actual work involved. Parallel construction is a form of false evidence in which the evidence is truthful but its origins are untruthfully described, at times in order to avoid evidence being excluded as inadmissible due to unlawful means of procurement such as an unlawful search.
Roger Keith Coleman was an American convicted murderer and rapist who was executed on May 20, 1992, for the rape and murder of his 19-year-old sister-in-law, Wanda Faye McCoy, at her home in Grundy, Virginia, on the night of March 10, 1981. A lifelong resident of Grundy, Coleman had worked as a coal miner.
Henry Watkins Skinner was an American death row inmate in Texas. In 1995, he was convicted of bludgeoning to death his live-in girlfriend, Twila Busby, and stabbing to death her two adult sons, Randy Busby and Elwin Caler. On March 24, 2010, twenty minutes before his scheduled execution, the U.S. Supreme Court issued a stay of execution to consider the question of whether Skinner could request testing of DNA his attorney chose not to have tested at his original trial in 1994. A third execution date for November 9, 2011, was also ultimately stayed by the Texas Court of Criminal Appeals on November 7, 2011.
Holmes v. South Carolina, 547 U.S. 319 (2006), was a decision by the United States Supreme Court involving the right of a criminal defendant to present evidence that a third party instead committed the crime. The Court vacated the rape and murder conviction in South Carolina of a man who had been denied the opportunity to present evidence of a third party's guilt, because the trial court believed the prosecutor's forensic evidence was too strong for the defendant's evidence to raise an inference of innocence. The Court ruled unanimously that this exclusion violated the right of a defendant to have a meaningful opportunity to present a complete defense, because the strength of a prosecutor's case had no logical relationship to whether a defendant's evidence was too weak to be admissible.
Frederick Salem Zain was an American forensic laboratory technician in West Virginia and Bexar County, Texas, who falsified serology results to obtain convictions.
Channon Gail Christian, aged 21, and Hugh Christopher Newsom Jr., aged 23, were from Knoxville, Tennessee, United States. They were kidnapped on the evening of January 6, 2007, when Christian's vehicle was carjacked. The couple were taken to a rental house. Both of them were raped, tortured, and murdered. Four males and one female were arrested, charged, and convicted in the case. In 2007, a grand jury indicted Letalvis Darnell Cobbins, Lemaricus Devall Davidson, George Geovonni Thomas, and Vanessa Lynn Coleman on counts of kidnapping, robbery, rape, and murder. Also in 2007, Eric DeWayne Boyd was indicted by a federal grand jury of being an accessory to a carjacking, resulting in serious bodily injury to another person and misprision of a felony. In 2018, Boyd was indicted on state-level charges of kidnapping, robbery, rape, and murder.
James Calvin Tillman is a man who was wrongfully convicted of rape, and served 18.5 years in prison before being exonerated by DNA testing on July 11, 2006. Tillman, of East Hartford Connecticut, was convicted of kidnapping in the first degree, sexual assault in the first degree, robbery and assault in the third degree in 1989, and freed in 2007.
Schlup v. Delo, 513 U.S. 298 (1995), was a case in which the United States Supreme Court expanded the ability to reopen a case in light of new evidence of innocence.
Celia Natasha "Tasha" Douty was a British-born Australian resort worker who was murdered on Brampton Island in Queensland, Australia. The crime remained unsolved until 2001, when Sydney motor industry finance Business Manager, Wayne Butler, was found guilty. It was the first murder in Australia to be solved using DNA profiling. The prosecution relied heavily on DNA evidence and it became a case study for the use of the technique in court.
Payne v. Tennessee, 501 U.S. 808 (1991), was a United States Supreme Court case authored by Chief Justice William Rehnquist which held that testimony in the form of a victim impact statement is admissible during the sentencing phase of a trial and, in death penalty cases, does not violate the Cruel and Unusual Punishment Clause of the Eighth Amendment. Payne overturned two of the Courts' precedents: Booth v. Maryland (1987) and South Carolina v. Gathers (1989).
Rolando Cruz is an American man known for having been wrongfully convicted and sentenced to death, along with co-defendant Alejandro Hernandez, for the 1983 kidnapping, rape, and murder of 10-year-old Jeanine Nicarico in DuPage County, Illinois. The police had no substantive physical evidence linking the two men to the crime. Their first trial was jointly in 1987, and their statements were used against each other and a third defendant.
Hae Min Lee was a Korean-American high school student who went missing on January 13, 1999, in Baltimore County, Maryland, before turning up dead on February 9, 1999, when her corpse was discovered in Leakin Park, Baltimore. Her autopsy revealed that she had been killed by way of manual strangulation.
Juan A. Rivera Jr. is an American man who was wrongfully convicted three times for the 1992 rape and murder of 11-year-old Holly Staker in Waukegan, Illinois. He was convicted twice on the basis of a confession that he said was coerced. No physical evidence linked him to the crime scene. In 2015 he received a $20 million settlement from Lake County, Illinois for wrongful conviction, formerly the largest settlement of its kind in United States history.
With no witnesses to the murders of Nicole Brown Simpson and Ron Goldman, DNA evidence in the O. J. Simpson murder case was the key physical proof used by the prosecution to link O. J. Simpson to the crime. Over nine weeks of testimony, 108 exhibits of DNA evidence, including 61 drops of blood, were presented at trial. Testing was cross-referenced and validated at three separate labs using different tests with no discrepancies found. The prosecution offered the defense access to the evidence samples to conduct their own testing, but they declined.
The Eastburn family murders were the murders of Kathryn "Katie" Eastburn and her daughters, Kara and Erin, which occurred in Fayetteville, North Carolina, in May 1985. In 1986, United States Army Sergeant Timothy Hennis was tried and convicted for the three murders. In 1988, Hennis's conviction was overturned on appeal, and he was acquitted the following year. In 2006, the Cumberland County Sherriff's Office obtained DNA evidence linking Hennis to the crime. Despite the Fifth Amendment's Double Jeopardy Clause prohibiting retrials after acquittals, the United States Army was able to initiate prosecution and trial proceedings against Hennis under the dual sovereignty doctrine. In 2010, Hennis was tried and convicted by an Army court-martial for the triple murders and sentenced to death.