Tuesday, November 5, 2013

House v. Bell case brief

House v. Bell case brief summary
547 U.S. 518 (2006)

Petitioner prison inmate, who was convicted in state court of murder and sentenced to death, asserted that new evidence indicated that he was actually innocent of the crime. Upon the grant of a writ of certiorari, the inmate challenged the judgment of the U.S. Court of Appeals for the Sixth Circuit which affirmed a denial of habeas corpus relief on the ground that the inmate failed to show actual innocence to preclude procedural default.

The inmate's constitutional claims were barred based on state procedural rules, but the inmate contended that evidence of his actual innocence was sufficient to except his claims from procedural default. The inmate asserted that new evidence conclusively established that sperm on the victim's clothes was that of the victim's husband and indicated that bloodstains on his clothes resulted from spillage from samples of the victim's blood and that the victim's husband was the likely murderer.

  • The U.S. Supreme Court held that, while there was no showing of conclusive exoneration, consideration of the inmate's claims was warranted despite procedural default since it was more likely than not that no reasonable juror viewing the record as a whole would lack reasonable doubt. 
  • Although sexual assault was not an element of the offense, the sperm evidence was used to infer the inmate's motive and to support the death penalty, and the only other forensic evidence, the bloodstains, was shown to be of questionable origin. 
  • Further, testimony that the husband confessed and evidence that the alcoholic husband regularly abused the victim potentially indicated the husband as the murderer.

The judgment upholding the denial of habeas corpus relief was reversed, and the case was remanded for consideration of the inmate's procedurally barred claims.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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