WETZEL v. LAMBERT

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Case Basics
Docket No. 
11-38
Petitioner 
ohn E. Wetzel, Secretary, Pennsylvania Department of Corrections, et al.
Respondent 
James Lambert
Decided By 
Term:
Facts of the Case 

Bruce Reese and Bernard Jackson were brothers-in-law who had committed several robberies together in the past; James Lambert was a newcomer to the group. On September 23, 1982, they agreed to rob a bar in Philadelphia, eventually settling on Prince’s Lounge. During the robbery, one man walked to the rear bar and pointed a gun in the face of a barmaid, Janet Ryan. A different man instructed another barmaid, Sarah Clark, to “get the money.” While Clark was placing money in a bag, she heard two gunshots from the back of the bar; a single actor had shot and killed two patrons.

Two weeks later, Jackson identified Lambert and Reese while in custody for an unrelated robbery. Lambert and Reese were tried jointly, with Jackson testifying against them. Janet Ryan also testified, and was at first unable to identify Lambert; shortly after stepping down from the stand, however, she approached the prosecutor and indicated that Lambert was the man who pointed the gun in her face. No other witness was able to identify Lambert or Reese, but the jury found Lambert guilty of two counts of first-degree murder, robbery, criminal conspiracy, and possession of an instrument of crime. He was sentenced to death.

A few months later, the Federal Capital Habeas Corpus Unit of the Federal Defender Association of Philadelphia seized the police investigatory file in what was later ruled to be an abuse of subpoena power. Lambert’s lawyers declared that several seized documents should have been available to the defense at trial, filing a claim under Pennsylvania’s Post Conviction Relief Act. One document indicated that Jackson named a “Lawrence Woodlock” as a co-defendant. The district court denied this claim, concluding that there was no reasonable likelihood the disclosure would have changed the verdict. The Pennsylvania Supreme Court affirmed, holding that the additional evidence was not significant because the defense had already thoroughly impeached Jackson’s testimony. The United States Court of Appeals for the Third Circuit reversed, reasoning that Jackson’s statement about an additional co-defendant opened up an entirely new line of impeachment.

Question 

Did the Third Circuit properly apply the habeas deference standard to the state courts’ rejection of Lambert’s claim?

Conclusion 
Decision: 6 votes for Lambert, 3 vote(s) against
Legal provision: federal habeas corpus

No. In a per curiam opinion, the Court held that the Third Circuit improperly rejected the state courts’ reasonable conclusion about the contents of the document. It cited the Antiterrorism and Effective Death Penalty Act of 1996, which precluded a federal court from granting a writ of habeas corpus to a state prisoner unless the adjudication of his claim by state courts involved an unreasonable application of federal law.

The Court argued that the Third Circuit overlooked the determination of the state courts that the documents were entirely ambiguous; instead, the Third Circuit focused solely on the state courts’ statements on the impeachment value of the evidence. The Court noted that the document did not explicitly link Woodlock to the Prince’s Lounge robbery, that Jackson committed a dozen or so similar robberies, that Jackson was being held on several charges while the document was prepared, that Woodlock’s name didn’t appear anywhere else in the evidence, and that the two barmaids did not verify Woodlock’s involvement.

Justice Stephen Breyer dissented, joined by Justices Ruth Bader Ginsburg and Elena Kagan. He disputed the majority’s notion that the document was entirely ambiguous, and moreover argued that the state courts did not arrive at that conclusion at all. Instead, Justice Breyer pointed out that the Pennsylvania Supreme Court was merely quoting the state’s argument, not agreeing with it. He would have denied the petition for a writ of certiorari because the question was a fact-specific determination applying well-established legal principles.

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WETZEL v. LAMBERT. The Oyez Project at IIT Chicago-Kent College of Law. 13 December 2014. <http://www.oyez.org/cases/2010-2019/2011/2011_11_38>.
WETZEL v. LAMBERT, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2011/2011_11_38 (last visited December 13, 2014).
"WETZEL v. LAMBERT," The Oyez Project at IIT Chicago-Kent College of Law, accessed December 13, 2014, http://www.oyez.org/cases/2010-2019/2011/2011_11_38.