Supreme Court Grants Tennessee Death Row Inmate New Hearing Based on DNA Evidence

The U.S. Supreme has expand­ed the abil­i­ty of death row inmates to chal­lenge their con­vic­tions in fed­er­al court based on DNA evi­dence pro­duced long after their tri­als. The rul­ing marks the first time that the Justices have con­sid­ered the new evi­den­tiary tech­nol­o­gy of DNA evi­dence when re-exam­in­ing a death sen­tence. In its 5 – 3 deci­sion, the Court held that new evi­dence, includ­ing DNA test results, raised suf­fi­cient doubt to mer­it a new hear­ing in fed­er­al court for Tennessee death row inmate Paul House, who was sen­tenced to death two decades ago for the rape and mur­der of his neigh­bor.

Writing for the major­i­ty in House v. Bell, Justice Anthony M. Kennedy not­ed, ​“Although the issue is close, we con­clude that this is the rare case where — had the jury heard all the con­flict­ing tes­ti­mo­ny — it is more like­ly than not that no rea­son­able juror view­ing the record as a whole would lack rea­son­able doubt.” Justice Kennedy iden­ti­fied three aspects of House’s case that, when con­sid­ered as a whole, qual­i­fied him to gain access to a habeas cor­pus hear­ing in fed­er­al court. The first piece of new evi­dence was recent DNA test results find­ing that House was not the source of semen found in the mur­der vic­tim, but that the source was instead the vic­tims’ hus­band. Second, new state­ments from three wit­ness­es linked the vic­tims’ hus­band to the crime. Lastly, recent tests have cast doubt on the reli­a­bil­i­ty of blood evi­dence pre­sent­ed at House’s tri­al. Although pros­e­cu­tors told jurors that the vic­tims’ blood had been found on House’s blue jeans, new evi­dence has raised the prospect that the blood spat­tered on House’s jeans came from a vial of the vic­tims’ blood tak­en dur­ing an autopsy.

Justice Kennedy said that ​“all the evi­dence, old and new, incrim­i­nat­ing and excul­pa­to­ry” must be tak­en into account. He not­ed that when an inmate comes to fed­er­al court with evi­dence of inno­cence, ​“the court’s func­tion is not to make an inde­pen­dent fac­tu­al deter­mi­na­tion about what like­ly occurred, but rather to assess the like­ly impact of the evi­dence on rea­son­able jurors.”

(Associated Press, June 12, 2006, and New York Times, June 13, 2006) See Supreme Court and Innocence.