## Facts

- Carolyn Muncey was murdered in rural Tennessee in 1985; Paul Gregory House was convicted of first-degree murder and sentenced to death.
- The prosecution’s case was largely circumstantial and relied heavily on forensic evidence, including semen evidence presented as consistent with House and small bloodstains on House’s jeans consistent with the victim’s blood.
- Post-conviction DNA testing showed the semen on the victim’s clothing was from the victim’s husband, not House, undermining the prosecution’s rape-related theory.
- House presented new evidence suggesting the blood evidence on his jeans may have resulted from contamination during handling and storage of the victim’s blood samples.
- House also offered testimonial evidence developed in habeas proceedings suggesting the victim’s husband may have committed the murder, including a reported confession.

## Issues

1. Whether, in light of new reliable evidence, House satisfied the Schlup v. Delo “actual innocence” gateway by showing it is more likely than not that no reasonable juror would have found him guilty beyond a reasonable doubt.
2. Whether the federal habeas court, when applying the Schlup gateway, must assess the likely impact of all evidence (old and new) on reasonable jurors rather than evaluate new evidence in isolation.
3. Whether AEDPA provisions governing successive petitions and evidentiary hearings constrained the Schlup gateway analysis in this posture.

## Decision

- The Supreme Court reversed the Sixth Circuit and remanded for further proceedings.
- The Court held House made the demanding showing required to pass through the actual-innocence gateway, permitting federal review of otherwise procedurally defaulted constitutional claims.
- The Court evaluated the “newly supplemented record” as a whole and concluded the new evidence sufficiently weakened the central forensic proof and added support for an alternative-suspect theory.
- The Court rejected the State’s effort to import AEDPA standards tied to successive petitions or evidentiary-hearing limits into this gateway inquiry.
- Chief Justice Roberts, joined by Justices Scalia and Thomas, concurred in part and dissented in part, concluding the new evidence still left room for a reasonable juror to convict.

## Legal Principles

- A habeas petitioner may overcome procedural default by making a gateway showing of actual innocence under Schlup v. Delo: in light of new reliable evidence, it is more likely than not that no reasonable juror would convict beyond a reasonable doubt.
- The Schlup inquiry requires considering all evidence—trial evidence plus new evidence—and assessing how reasonable jurors would view the overall record.
- The gateway standard is probabilistic and does not require absolute certainty of innocence; it asks whether the supplemented record would leave reasonable jurors without proof beyond a reasonable doubt.
- Evidence undermining core forensic proof and evidence pointing to an alternative perpetrator may collectively satisfy the gateway even if neither category is independently conclusive.
- AEDPA provisions addressing successive petitions and evidentiary-hearing restrictions do not necessarily govern the Schlup gateway determination in a first federal habeas proceeding addressing procedural default.

## Conclusion

The Court held that House’s post-conviction DNA results and related new evidence, assessed together with the trial record, met the Schlup actual-innocence gateway standard, allowing federal courts to reach the merits of his otherwise procedurally defaulted habeas claims.


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