Ex Parte Joe Rene Elizondo, Applicant

Summary

The Court held that the Due Process Clause prohibits the incarceration of an innocent person and that a post‑conviction claim of actual innocence in a non‑capital case must be proved by clear and convincing evidence that no reasonable juror would have convicted the applicant in light of the newly discovered evidence. The majority granted habeas relief, while a dissent argued for a higher burden and a concurrence supported the majority’s standard. Justice Baird’s concurrence and Judge White’s dissent are summarized at the end of this summary.