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Supreme Court Decision Update - House v. Bell

supreme2.jpgIn today’s second case, House v. Bell (PDF of the Opinion), the Supreme Court - in a 5-3 decision - relaxed the guidelines for when a convicted criminal can obtain another round of appeals based on new evidence.

Quizlaw Analysis: Read with the Hill case, the Roberts Court seems to be softening their stance on death-row inmates. For the second time in a day, the Supremes reversed a lower court’s decision to deny an inmate another stab at a reprieve. Here, the court granted appeal even though the new evidence did not prove definitively that House was not guilty.

Paul Gregory House was convicted for the murder of Carolyn Muncey based, in part, on blood and semen evidence taken by the FBI. The jury in the case sentenced House to death because the semen evidence suggested both murder and rape. On appeal, House presented DNA evidence showing that the semen on Muncey’s shirt came from her husband, and that his blood was spilled on Muncey’s jeans after the murder while House’s blood sample and Muncey’s jeans were being transported by the police. There was also evidence not admitted at trial that Muncey’s husband could have been the murderer, including a history of domestic abuse, a fake alibi, and a confession.

The Supremes, in a decision written by Justice Kennedy, ruled that House had presented enough new evidence to justify an additional appeal, even though he’d already exhausted all of his other appeals. In an effort to balance the need to limit appeals with a convict’s right to present new evidence, especially in light of DNA testing and other scientific means, the Court basically ruled that a further appeal is warranted if new evidence might have changed the jury’s verdict, even if the offered evidence does not outright exonerate him. “He has cast doubt on his guilt sufficient to satisfy [the] gateway standard for obtaining federal review,” Kennedy wrote, even though “his showing falls short of the threshold” to prove actual innocence.

Judge Roberts wrote separately to concur in the judgment in part, and dissent in part. Joined by Justices Scalia and Thomas, Roberts would keep the standard for a new appeal much higher. Under his standard, a new appeal would only be allowed if the new evidence is reliable and conclusive enough so that “no reasonable juror would vote to convict him.”

Alito did not participate in the opinion.