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House v. Bell | 547 U.S. 518 (2006)

In 1985, Carolyn Muncey was violently murdered in rural Tennessee. 21 years later, the search for her murderer arrived at the United States Supreme Court in House versus Bell.

Circumstantial evidence pointed to Paul House as the murderer. He’d lied to police regarding his whereabouts and had previously been convicted of sexual assault. But Carolyn’s husband, William Muncey, also didn’t have a reliable alibi.

Officers seized the blue jeans House wore that night. Genetic-testing technology hadn’t been invented yet. But at House’s capital murder trial, a Federal Bureau of Investigation serologist testified that semen samples recovered from Carolyn’s nightgown were consistent with House’s blood group antigens. But they were also consistent with a large percentage of the general population. Blood found on House’s jeans was type A. House, Carolyn, and William all had type A blood.

The prosecutor argued that House cajoled Carolyn out of her house, transported her elsewhere, tried to rape her, then killed her in anger. The prosecution also argued that the blood antigen evidence pointed to House. The jury convicted House, and he was sentenced to death. The Tennessee Supreme Court affirmed.

House filed a petition for postconviction relief, which was also denied.

Several years later, House again petitioned for postconviction relief. The state courts held that any new claims not raised in the prior postconviction petition were waived and denied his petition. House then sought federal habeas relief.

At a district court evidentiary hearing, F B I experts testified that D N A testing proved that the semen on Carolyn’s clothing came from William, not from House. Moreover, chemical analysis indicated that the blood found on House’s blue jeans couldn’t have come directly from Carolyn’s body but came from vials of Carolyn’s blood taken during her autopsy. The vials had been stored with and leaked onto House’s jeans. Finally, while the jury heard that the Munceys had fought, several witnesses now testified that William regularly abused Carolyn. Two other witnesses testified that William had admitted to killing Carolyn. But William testified, denying that he killed Carolyn or admitted to it.

Nevertheless, the district court determined that House hadn’t established his actual innocence and granted the state summary judgment. A Sixth Circuit panel affirmed the judgment in a split decision, and the en banc court, in a six-to-five decision, also affirmed. The United States Supreme Court granted cert.

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