House v. Bell

Facts

Local residents found Muncey's body concealed amid brush and tree branches on an embankment roughly 100 yards up the road from her driveway. She was seen last on the prior day around 8 p.m. The time of death was between 9 and 11 p.m. Mrs. Muncey had a black eye, both her hands were bloodstained up to the wrists, and she had bruises on her legs and neck. The bruises were consistent with a 'traumatic origin,' i.e., a fight or a fall on hard objects. It was concluded Mrs. Muncey had been choked, but he ruled this out as the cause of death. The cause of death, in Dr. Carabia's view, was a severe blow to the left forehead that inflicted both a laceration penetrating to the bone and, inside the skull, a severe right-side hemorrhage, likely caused by Mrs. Muncey's brain slamming into the skull opposite the impact. The head injury was consistent either with receiving a blow from a fist or other instrument or with striking some object. D was questioned shortly after the body was found. That evening, House answered further questions during a voluntary interview at the local jail. D claimed--falsely that he spent the entire evening with his girlfriend, Donna Turner, at her trailer. Asked whether he was wearing the same pants he had worn the night before, D replied--again, falsely--that he was. D was on probation at the time, having recently been released on parole following a sentence of five years to life for aggravated sexual assault in Utah. D had scratches on his arms and hands, and a knuckle on his right ring finger was bruised. He attributed the scratches to his girlfriend's cats and the finger injury to recent construction work tearing down a shed. Turner informed authorities that D left her trailer around 10:30 or 10:45 p.m. to go for a walk. D returned later--she was not sure when--hot and panting, missing his shirt and his shoes. D claimed that he had been assaulted by someone in a car who fired two shots at him. Turner testified that she 'thought maybe he ex-husband had something to do with it.' Turner's trailer was located just under two miles by road, through hilly terrain, from the Muncey residence. Law enforcement officers also questioned the victim's husband. Mr. Muncey had spent the evening at a weekly dance at a recreation center roughly a mile and a half from his home. Mr. Muncey admitted leaving the dance early but said it was only for a brief trip to the package store to buy beer. He also stated that he and his wife had had sexual relations Saturday morning. Police seized the pants D was wearing the night Mrs. Muncey disappeared. The heavily soiled pants were sitting in a laundry hamper. FBI testing revealed human blood on the pants and D was arrested. D was charged House with capital murder. FBI testing showed--that semen consistent (or so it seemed) with D's was present on Mrs. Muncey's nightgown and panties, and that small bloodstains consistent with Mrs. Muncey's blood but not D's appeared on the jeans belonging to D. The semen was from the ABO blood group a characteristic shared by 80 percent of the population, including D. The source of semen on the gown was blood-type A, D's own blood type. As to the semen on the panties, they found only the H blood-group substance, which A and B blood-type secretors secrete along with substances A and B, and which O-type secretors secrete exclusively. P claimed that Ds A antigens could have 'degraded' into H. P concluded that both semen deposits could have come from D, though he acknowledged that the H antigen could have come from Mrs. Muncey herself if she was a secretor--something he 'was not able to determine.' Mr. Muncey was himself blood-type A (as was his wife). It was acknowledged that 'a saliva sample' would have sufficed to determine whether Mr. Muncey was a secretor; the State did not provide such a sample, though it did provide samples of Mr. Muncey's blood. It was determined that the blood's source was type A (the type shared by D, the victim, and Mr. Muncey). Fiber analysis showed blue jean material, but it was admitted that such material was commonplace. It was also admitted that D's pants, though cotton garments both transfer and retain fibers readily and neither hair nor fiber consistent with the victim's hair or clothing was found on D's pants. D's shoes were found several months after the crime in a field near Turner's home. Turner delivered them to authorities. The jury nor D never learned of that. P tested the shoes for blood and found none. D's shirt was not found. In closing argument, P argued that a death occurred during the perpetration of a rape or kidnapping. The jury found D guilty of murder in the first degree. At sentencing, the jury found aggravation and recommended the death penalty, which the trial judge imposed. The Tennessee Supreme Court affirmed D's conviction and sentence, describing the evidence against D as 'circumstantial' but 'quite strong.' D filed a pro se petition for post-conviction relief, arguing he received ineffective assistance of counsel at trial. The trial court dismissed the petition. The Tennessee Court of Criminal Appeals affirmed, and both the Tennessee Supreme Court and the Supreme Court denied review. D filed a second post-conviction petition in state court reasserting his ineffective-assistance claim and seeking investigative and/or expert assistance. The Tennessee Supreme Court held that D's claims were barred under a state statute providing that claims not raised in prior post-conviction proceedings are presumptively waived and that courts may not consider grounds for relief 'which the court finds should be excluded because they have been waived or previously determined.' The Supreme Court denied certiorari. D sought federal habeas relief, asserting numerous claims of ineffective assistance of counsel and prosecutorial misconduct. The District Court held an evidentiary hearing to determine whether D fell within the 'actual innocence' exception to procedural default recognized as to substantive offenses in Schlup and as to death sentences in Sawyer v. Whitley. D attacked the semen and blood evidence used at his trial and presented other evidence, including a putative confession, suggesting that Mr. Muncey, not D, committed the murder. The District Court denied relief, holding that House had neither demonstrated actual innocence of the murder under Schlup nor established that he was ineligible for the death penalty under Sawyer. The Sixth Circuit affirmed, but its opinion was withdrawn and the case taken en banc. A divided en banc court certified state-law questions to the Tennessee Supreme Court. The Tennessee Supreme Court did not answer. The case returned to the United States Court of Appeals for the Sixth Circuit. This time an eight-judge majority affirmed the District Court's denial of habeas relief. The Supreme Court granted certiorari.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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