House V. Bell - Background

Background

In 1985, Carolyn Muncey was bludgeoned to death in Luttrell, Tennessee, near Knoxville. Her body was found on an embankment the following day. Paul Gregory House, who was a friend of the Munceys, was charged with the murder. House was on parole and had a prior aggravated sexual assault conviction in Utah Based on circumstantial evidence that House was spotted near the embankment, that blood consistent with that of the victim was found on House's jeans, and that semen consistent with House's was found on the victim's nightgown and underwear, House was found guilty at trial with aggravating factors that qualified him for capital punishment.

The Tennessee Supreme Court affirmed House's conviction and sentence, describing the evidence against House as "circumstantial" but "quite strong." Later, in a state trial court, House filed a pro se petition for post-conviction relief, arguing that he received ineffective assistance of counsel at trial and objecting to certain jury instructions. At a hearing before the same judge who conducted the trial, the court dismissed the petition, deeming House's trial counsel adequate and overruling House's other objections. On appeal House's attorney renewed only the jury-instructions argument and the Tennessee Court of Criminal Appeals affirmed, and both the Tennessee Supreme Court and the Supreme Court of the United States denied review.

House filed a second post-conviction petition in state court reasserting his ineffective-assistance claim. After extensive litigation regarding whether House's claims were procedurally defaulted, the Tennessee Supreme Court held that House's claims were barred under a state statute providing that claims not raised in prior post-conviction proceedings are presumptively waived.

House next sought federal habeas corpus relief, asserting numerous claims of ineffective assistance of counsel and prosecutorial misconduct.

In November 2002, the United States Court of Appeals for the Sixth Circuit reviewed the case in light of new DNA evidence that might exonerate House. The DNA taken from semen on the victim's clothing matched her husband, and not House. Additionally, House advanced the theory that the blood found on his jeans was spilled onto them from autopsy samples while the evidence was being transported from Tennessee to the FBI crime lab. Two witnesses also came forward to say that the victim's husband, Hubert Muncey, had confessed to the murder. In light of the new evidence, the Court of Appeals referred the case to the Tennessee Supreme Court, asking it to consider how the state law barring consideration of claims not raised in prior post-conviction appeals applies in this situation.

In December 2003, the Tennessee Supreme Court refused to consider whether new DNA evidence presented during death penalty appeals necessitates a new trial, and declined to answer other questions posed. The Tennessee Supreme Court sent the case back to the Federal Court of Appeals. The Federal Court of Appeals narrowly rejected House's appeal on October 6, 2004, in a 8-7 decision with strongly worded opinions from the dissenting judges.

On June 28, 2005, the U.S. Supreme Court agreed to take up the case, to reconsider under what circumstances death penalty cases could be reopened in light of new evidence.