School Essay: House v. Bell, Warden Decided June 12, 2006

House

v.

Bell, Warden Decided June 12, 2006

(Cite as: 547 U.S. 518 (2006))

Facts: The defendant, Paul House, was found guilty by a Tennessee jury of the murder and rape of Carolyn Muncey and was sentenced to death (House v. Bell, Warden, 2013).  During the trial, prosecution produced incriminating evidence against House that included blood, Semen, and other physical evidence (House v. Bell, Warden, 2013).  During the sentencing phase of House, "the jury found, inter alia, the aggravating factor that the murder was committed while House was committing, attempting to commit, or fleeing from the commission of rape or kidnapping" (House v. Bell, Warden, 2013).  House then requested for federal habeas corpus relief for claims that were procedurally barred in the state court on the basis of actual innocence but he was denied by the federal court (House v. Bell, Warden, 2013).  House then tried to prove that the blood and semen was in fact that of Mr. Muncey's along with other evidence to suggest that Mr. Muncey did the crime, however, House "did not fall within the actual innocence exception to procedural default recognized in Schlup v. Delo and Sawyer v. Whitley" (House v. Bell, Warden, 2013).  The decision was affirmed by the Sixth Circuit (House v. Bell, Warden, 2013).

Issue: The issue in this case is whether the federal court of appeals made an error when they applied Schlup v. Delo to hold that the evidence House presented was legally insufficient to excuse his failure to present that evidence in state court (House v. Bell, Warden, 2013).  "What constitutes a "truly persuasive showing of actual innocence" pursuant to Herrera v. Collins sufficient to warrant freestanding habeas relief" (House v. Bell, Warden, 2013).  Another issue is how much evidence must a defendant expect to present "to prove his actual innocence to obtain habeas corpus relief of procedurally defaulted claims under Schlup v. Delo and Herrera v. Collins (House v. Bell, Warden, 2013)?

Holding:  It was held that House's federal habeas action could proceed because he had prepared the inflexible showing required by the actual innocence exception (House v. Bell, Warden, 2013).  The Supreme Court did not conclusively exonerate House but did conclude that if the jury had heard all of the conflicting testimony, a reasonable jury most likely would not have been convinced of House's guilt beyond a reasonable doubt (House v. Bell, Warden, 2013).

Reasons: "A defendant may not be granted federal habeas corpus review unless the petitioner provides sufficient evidence which would result in a different outcome of his/her case" (House v. Bell, 2011).

          In closing, the fact that Paul House was convicted and sentenced to death merely on circumstantial evidence is a frightening prospect.  Because he had a prior offense, the circumstantial evidence against him became all the more powerful.  However, House fought tooth and nail, was denied several times, but eventually he was able to provide enough evidence that could potentially change the outcome of the case.  Was Hubert Muncey, Carolyn Muncey's husband,  the actual guilty party?  There was enough circumstantial evidence to point at both men equally.  In the end, Paul House was exonerated after spending 22 years on Tennessee death row (Grinberg, 2009).  Who killed Carolyn Muncey's?  We may never know for sure. 

Works Cited

Grinberg, E. (2009, 05 14). Exonerated death row inmate: 'took 'em long enough'. Retrieved 05 11, 2013, from CNN: http://www.cnn.com/2009/CRIME/05/13/tennessee.exonerated/

House v. Bell. (2011, 10 29). Retrieved 05 11, 2013, from Court Cases and Discussion: http://cobaintwist.blogspot.com/2011/10/house-v-bell-547-us-518-126-s-ct-2064.html

House v. Bell, Warden. (2013). Retrieved 05 11, 2013, from FindLaw: http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=us&vol=000&invol=04-8990