The U.S. Supreme Court case Paul Gregory House v. Ricky Bell, Warden (2005) revolved around the issue of whether new evidence that emerged after a trial could be considered in determining if a death row inmate should receive habeas corpus relief from his sentence. The petitioner, Paul Gregory House, was convicted for murder and sentenced to death in Tennessee state court but later presented DNA evidence suggesting that he did not commit the crime. The District Court denied him relief and the Sixth Circuit affirmed this decision on appeal because they believed that even with this new evidence, no juror would have reasonable doubt about House's guilt. However, when it reached the Supreme Court level, justices ruled 5-3 in favor of House stating that considering all pieces of evidences together including those introduced post-trial created sufficient doubt about his guilt which might have led to a different outcome at trial had they been available then. Therefore it concluded that such cases where "it is more likely than not" any reasonable juror would have reasonable doubts are rare but do qualify for habeas corpus relief under federal law.

In the dissenting opinion for Paul Gregory House v. Ricky Bell, Warden (2005), Justice Clarence Thomas, joined by Justice Antonin Scalia, argued that the majority had misapplied a standard of review established in an earlier case (Schlup v. Delo) and overstepped its authority by reevaluating evidence and witness credibility - tasks typically reserved for state courts during post-conviction proceedings. The dissenters contended that House failed to meet his burden under Schlup because he did not show it was more likely than not that no reasonable juror would have convicted him in light of new evidence. They also criticized the majority's reliance on DNA testing results which were inconclusive due to contamination issues and their dismissal of other compelling circumstantial evidence against House such as his suspicious behavior after the crime occurred.