Court sides with death row inmate, allowing DNA appeal
The justices say new DNA evidence – even if not proof of innocence – merits another appeal for man on death row.
WASHINGTON — A Tennessee death-row inmate has won the right to reopen his case to examine evidence that he says shows someone else committed the murder for which he has been sentenced to die.
In a 5-to-3 ruling Monday, the US Supreme Court said that inmate Paul House had presented enough evidence to justify granting a new appeal even though he had exhausted all his appeals.
The decision in the case House v. Bell is important because it establishes somewhat easier guidelines for when newly obtained evidence – such as DNA test results – may entitle a convicted criminal to another round of appeals.
The House case did not involve concrete evidence of guilt or innocence that might lead to an immediate exoneration. Instead, the question was how much weight to give such scientific and other evidence in more murky cases where guilt or innocence is still a question to be resolved by a jury.
The court was asked to decide whether in light of newly discovered evidence that conflicts with evidence presented at Mr. House's trial, a reasonable juror would find him guilty of murder.
Congress and the courts have acted in recent years to sharply limit the number of appeals available to convicted murderers. But at the same time DNA testing has helped exonerate 180 individuals, according to the Innocence Project.
The House case offered the high court an opportunity to establish what it views as the proper balance between limiting appeals and permitting courts to closely examine new evidence of innocence.
Mr. House was convicted of the July 1985 murder of Carolyn Muncey, a mother of two young children, in Union County, Tenn. Mrs. Muncey's badly beaten body was found near her home.
Two witnesses saw House near the woods where the body was found, and House and others gave conflicting statements about his whereabouts at the time of the murder. In addition, the FBI testified that it found Muncey's blood on House's jeans and his semen on her clothing.
A jury found House guilty of murder and sentenced him to death.
On appeal, lawyers for House argued that their client was innocent. They presented a DNA test that showed the semen on Muncey's clothing came from her husband, not House. They also presented evidence suggesting Muncey's blood was spilled on House's jeans after the murder while a blood sample and the jeans were being transported together by police for testing.
Defense lawyers also presented testimony from witnesses who said they heard Muncey's husband confess to killing her.
None of the state and federal courts that heard the appeal agreed that House had presented enough evidence that he was actually innocent to warrant a new appeal.
On Monday, the Supreme Court reversed the lower court, ruling that House had presented enough evidence.
"This is not a case of conclusive exoneration," writes Justice Anthony Kennedy for the majority. "Some aspects of the state's evidence ... still support an inference of guilt. Yet the central forensic proof connecting House to the crime – the blood and the semen – has been called into question," Justice Kennedy writes. He adds that House has "put forward substantial evidence pointing to a different suspect."
Kennedy says that although the issue is close, House's is the "rare" case that meets the strict standard for permitting a new appeal even though the evidence falls short of proving "actual innocence."
Joining the majority opinion were Justices John Paul Stevens, David Souter, Ruth Bader Ginsburg, and Stephen Breyer.
Chief Justice John Roberts filed a dissent, joined by Justices Antonin Scalia and Clarence Thomas. Justice Samuel Alito did not participate in the case because it was argued before he joined the court.
In his dissent, Chief Justice Roberts said the judicial standard that should be applied in House's case is one of actual innocence. "The question is not whether House was prejudiced at his trial because the jurors were not aware of the new evidence, but whether all the evidence, considered together, proves that House was actually innocent, so that no reasonable juror would vote to convict him," Roberts writes.