Supreme Court Review-Preview-Overview

An up-to-date outline of Supreme Court criminal cases
is available here. It covers pending cert grants and decisions from the past and current Terms. Other "cites" of interest are available here.

Monday, June 12, 2006

House: Habeas Relief on Defaulted Actual Innocence Claim

In House v. Bell, No. 04-8990 (June 12, 2006), the Supreme Court held that a Tennessee death row inmate had made the stringent showing required of a habeas petitioner who seeks to assert a defaulted challenge to his conviction based on "actual innocence." House was able to show that it was more likely than not that no reasonable juror would have found him guilty beyond a reasonable doubt, had the juror been aware of new evidence, including evidence that (1) semen found on the victim did not belong to House, and this removed the motive for the crime (sexual assault), (2) substantial doubts had been raised about the origin of blood found on the House’s clothing (the blood had originally been linked to the victim), and (3) the victim’s husband purportedly confessed to her murder.
The Court noted that House had not established "freestanding innocence" that would render his conviction and sentence unconstitutional. He had raised sufficient doubts about his innocence, however, to warrant further consideration of his habeas petition.