Lambert v. Blackwell

Rule of Law:

Under the Antiterrorism and Effective Death Penalty Act (AEDPA), federal courts must afford considerable deference to state court factual and legal determinations, and may not grant habeas relief unless the state court's adjudication was contrary to, or an unreasonable application of, clearly established federal law, or was based on an unreasonable determination of the facts.

Facts:

• Lisa Lambert and Lawrence Yunkin were in a romantic relationship. Yunkin had a brief previous relationship with the 15-year-old victim, Laurie Show.
• Significant animosity existed between Lambert and Show, marked by prior physical altercations, harassment, and numerous threats by Lambert to kill Show, including mentioning she would slit Show's throat.
• On December 19, 1991, Lambert purchased rope and two knit hats. That same evening, an unidentified person called Laurie Show's mother, Hazel Show, posing as a school guidance counselor to lure her away from home with a fictitious meeting the next morning.
• On the morning of December 20, 1991, while Hazel Show was away at the fictitious meeting, Lambert, Yunkin, and their friend Tabitha Buck drove to the victim's condominium complex.
• Lambert and Buck entered Laurie Show's apartment, carrying a knife from Lambert and Yunkin's home.
• A struggle ensued inside the apartment, during which Laurie Show was stabbed in the back and her throat was slit, causing fatal injuries.
• After the attack, Lambert, Buck, and Yunkin fled together, concocted an alibi, and disposed of evidence, including bloody clothing and the murder weapon, which they threw into the Susquehanna River.
• When Hazel Show returned home, she found her daughter dying. Hazel Show testified at trial that Laurie Show's last words were, 'Michelle did it.'

Procedural Posture:

• Lisa Lambert was convicted of first-degree murder after a bench trial in the Court of Common Pleas for Lancaster County, Pennsylvania, and was sentenced to life in prison.
• Lambert's conviction and sentence were affirmed on direct appeal in the Pennsylvania state courts, and the Pennsylvania Supreme Court denied review.
• Lambert filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Pennsylvania. The district court granted the petition, finding Lambert 'actually innocent' and barring any retrial.
• The Commonwealth appealed, and the U.S. Court of Appeals for the Third Circuit vacated the district court's judgment, ruling that Lambert had failed to exhaust her available state court remedies.
• Lambert then filed a petition under the Pennsylvania Post Conviction Relief Act (PCRA) in the state trial court. After an extensive evidentiary hearing, the PCRA court denied her petition.
• The Pennsylvania Superior Court affirmed the denial of PCRA relief. Lambert did not seek an allowance of appeal from the Pennsylvania Supreme Court.
• Lambert re-filed her habeas petition in the U.S. District Court. After the initial judge recused himself, the case was reassigned to Judge Anita Brody.
• Judge Brody, applying AEDPA deference to the state court findings, denied Lambert's petition and dismissed it with prejudice. Lambert appealed this dismissal to the U.S. Court of Appeals for the Third Circuit.