Han Lee v. Superintendent Houtzdale SCI, 798 F.3d 159

In 1990 Han Tak Lee was convicted of arson and first-degree murder for the death of his daughter at a cabin; conviction relied heavily on contemporary fire‑science and gas‑chromatography testimony.
Subsequent scientific developments have discredited the fire‑science and chromatographic methods used at trial; the Commonwealth concedes those portions are unreliable.
Lee pursued state post‑conviction relief and then a § 2254 habeas petition alleging due‑process violations because his conviction rested on inaccurate scientific evidence.
The District Court granted habeas relief after an evidentiary hearing, concluding the tainted expert evidence undermined the trial’s fundamental fairness and there was not "ample other evidence" of guilt.
The Commonwealth appealed; procedural disputes included timeliness and electronic‑filing objections to the notice of appeal, which the Third Circuit rejected and retained jurisdiction.
On merits review (without AEDPA deference per earlier panel), the Third Circuit affirmed: the unreliable scientific evidence was central to the verdict and the remaining evidence (autopsy ambiguity, perceived nonchalance, minor inconsistencies) was insufficiently probative to sustain the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of now‑discredited fire‑science and chromatography evidence violated due process	Lee: Expert testimony was unreliable and its admission undermined trial fairness	Commonwealth: Other evidence provided "ample" proof of guilt despite flawed science	Held: Admission undermined fundamental fairness; habeas relief warranted because remaining evidence was not ample
Whether habeas relief required a freestanding innocence showing	Lee: Relief grounded in due‑process (not freestanding innocence) based on unreliable evidence	Commonwealth: Relief impermissible absent independent showing of innocence	Held: Not a freestanding innocence claim; due‑process claim sufficed (no innocence showing required)
Whether the Commonwealth’s notice of appeal was timely and valid despite local e‑filing violations	Lee: Paper filing violated local rules so appeal invalid	Commonwealth: Notice received by clerk within 30 days; Parissi controls	Held: Timely and effective on receipt by clerk; local e‑filing noncompliance did not defeat jurisdiction
Standard of review applicable to state‑court determinations (AEDPA deference)	Lee: Prior panel ruled AEDPA deference did not apply; review de novo	Commonwealth: Arguably would prefer AEDPA deference	Held: Court followed prior-panel (law‑of‑the‑case) and reviewed without AEDPA deference

Lee v. Glunt, 667 F.3d 397 (3d Cir. 2012) (prior panel ruling that deference did not apply and framing standard for due‑process challenge to tainted expert evidence)
Albrecht v. Horn, 485 F.3d 103 (3d Cir. 2007) (describing when "ample other evidence" can sustain a conviction despite error)
Parissi v. Telechron, Inc., 349 U.S. 46 (1955) (notice of appeal is filed when received by clerk; late fee payment or filing technicalities do not defeat timeliness)
Becker v. Montgomery, 532 U.S. 757 (2001) (notice‑of‑appeal defects should not be fatal where intent to appeal is clear)
Gov’t of the Virgin Islands v. Mills, 634 F.3d 746 (3d Cir. 2011) (commonsense approach to notice‑of‑appeal sufficiency)
Gould v. Members of the N.J. Div. of Water Pol’y and Supply, 555 F.2d 340 (3d Cir. 1977) (clerk must accept notices of appeal even without filing fee)
Nara v. Frank, 488 F.3d 187 (3d Cir. 2007) (plain‑error review applies where party fails to properly object to magistrate judge’s R&R)
Klemm v. Astrue, 543 F.3d 1139 (9th Cir. 2008) (paper notice received by clerk is effective notwithstanding local e‑filing rules)