Overview of House v Bell - Case Study Example

House v Bell, 547 U.S. 518 (2006) House was convicted for the murder of Carolyn Muncey and sentenced to death. Muncey’s badly beaten body was found a day after her death in a bush a hundred yards from her house. It was established that she died from a blow to her head. On the day the body was discovered, two witnesses saw House emerging, while wiping his hands with a dark rag, from the area where her body was discovered. His testimony, as well as that of other witnesses, about his whereabouts on the night of the murder was conflicting. During the course of investigations, police officers found blood on House’s trousers. Additionally, they found semen on Muncey’s garments. DNA analysis established that the blood on House’s trousers was from Muncey. The analysis also determined that the semen on Munceys garments were from House. House was sentenced to death based on three aggravating factors. These factors were; House had prior convictions, which involved threat of violence to persons; the current murder was cruel as it involved depravity of mind; and the murder occurred when the defendant was trying to commit rape or kidnapping. The prosecution’s argument relied on the fact that House was not at home when the murder occurred and he had misled the police on his whereabouts on the night of the murder. There was also the evidence of two witnesses who had seen House at the scene of the crime. Moreover, DNA analysis connected House to the murder victim. Although the evidence against the defendant was circumstantial, it was quite strong to warrant a conviction (Merritt 2008). After the conviction, House applied for a post-conviction relief from the trail court. Among the claims made in the petition was that the defendant received ineffective assistance from counsel during the trial. House did not present new evidence and relied on the trial transcript. His petition was denied by the trial court and on appeal he did not challenge the ruling on the ineffective counsel but alleged an error in jury instructions. The court denied relief on grounds that the claims had been adjudicated or waived in previous post-conviction hearings. After the outcome in the post-conviction relief hearings, House filed a habeas corpus relief in the District court. In this petition, he claimed ineffective assistance of counsel and that he was innocent and the prosecution had suppressed exculpatory evidence. The court granted summary judgment in favor of Bell but held an evidentiary hearing to determine his innocence for the crime, ineffective assistance of counsel and innocence of the death penalty. During this trial House presented evidence that had not been presented during trial. This evidence was DNA analysis that showed the semen found on the victims garments were not his but from the victim’s husband. There was also evidence that showed that the blood on his trousers was transferred during the investigations and not during the crime. House also gave an explanation about his whereabouts on the night of the murder and evidence about the confession by the victim’s husband of the murder. The court determined that the witnesses and House were not credible witnesses. Additionally, although the blood on his trousers was transferred during investigations and that the semen found did not belong to him, this evidence was not sufficient to demonstrate his innocence. Therefore, his other claims were bared because of procedural default. The Sixth Circuit Court of Appeals affirmed the lower court’s decision and noted that the case against him was still overwhelming. The court held that the evidence was not sufficient to meet the requirement set in Schulp v Delo. The case proceeded to the US Supreme Court (Dow, Taylor, Bourliot, & Jeans 2006). The issues before the Supreme Court were whether the federal court of appeals erred in applying Schulp v Delo in determining whether a constitutional violation resulted in the conviction of House due to his probability of innocence. The court also had to determine what constitutes a truly persuasive demonstration of innocence sufficient to support a habeas corpus relief under Herrera v. Collins The rule in Herrera v. Collins follows that "in a capital case a truly persuasive demonstration of 'actual innocence' made after trial would render the execution of a defendant unconstitutional, and warrant federal habeas relief if there were no state avenue open to process such a claim.” However, claims, which have defaulted under state law, do not qualify for a habeas corpus relief unless the petitioner offers adequate reason for the default and shows that the claimed error prejudiced the trial. An exception to this rule was established in Schulp v Delo. This exception applies where there is a miscarriage of justice in extraordinary cases. It requires individuals claiming innocence, as a gateway for review of defaulted claims, to show that in light of new evidence it would be likely that no reasonable juror would find the defendant guilty beyond reasonable doubt (Case 2008). The relief of habeas corpus allows an individual to challenge the propriety of custody. The essence of this relief is that it allows the defendant to petition the court to inquire into the legality of his imprisonment. In the current case, House brought the petition based on new evidence relating to his conviction. In the petition, House argued that the new evidence raised doubts about the fairness of his conviction and his guilt. His claim was that he was entitled to a habeas relief based on the Schulp gateway as well as the claim of innocence under Herrera. In his argument, House stated that the new evidence was sufficient to permit him to pass through the gateway. This allows him to bypass all technicalities that would bar him from making a claim of innocence. He further provides that the new evidence exceeds the standard set by Schulp and the lower courts erred in the application of Schulps to the facts in his case. In order for a claim under Schulp to succeed, there should be new and reliable evidence that was not presented during trial. The new DNA evidence contradicted evidence presented at trial. The DNA evidence presented at trial linked House to the murder and thus persuaded the jury to reach a guilty verdict. The new evidence would prevent any juror from placing reliance on the DNA evidence. There was also the evidence that there could have been a different suspect. From the analysis of the new evidence, it is apparent that a jury would have viewed the record with reasonable doubt. Additionally, House asked the court to determine if his claims were a “persuasive demonstration of actual innocence”. In Herrera, it was held that a persuasive demonstration of innocence made after conviction would make an execution unconstitutional and warrant a relief of habeas corpus (Reader 2009). The court held that the case of House was extraordinary that he could be granted a review despite of his failure to present the evidence at trial in the state court. This was because the new evidence presented was compelling that no reasonable juror would find him guilty beyond reasonable doubt. The court, however, declined to answer the question of “persuasive demonstration of actual innocence” established in Herrera. A post-conviction relief is an appeal to a criminal sentence that challenges a conviction that has become final in the ordinary appellate process. A post-conviction habeas corpus relief is granted only in exceptional circumstances. This rule is based on the principle of respect for judgments made by the appellate courts. An exception to this rule was established in Schulp v Delo and requires the availability of new evidence that creates reasonable doubt about the guilt of the applicant. Reference list Case, J. G. (2008). How wide should the actual innocence gateway be an attempt to clarify the miscarriage of justice exception for federal habeas corpus proceedings. Wm. & Mary L. Rev. 50, 669. Dow, D. R., Taylor, J., Bourliot, F., & Jeans, J. (2006). Is it constitutional to execute someone who is innocent (and if it isn’t, how can it be stopped following House v Bell). Tulsa L. Rev. 42, 277. Merritt Jr, G. S. (2008). Prosecutorial error in death penalty cases. Tenn. L. Rev., 76, 677. Reader, M. S. (2009). Post-conviction claims of innocence. Crim. Just., 24, 14. Read More