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By denying a petition for federal writ of habeas corpus, the ruling spotlights the late twentieth century role of federalism in constitutional criminal law. Federal courts increasingly deferred to state court systems in criminal justice cases. Actions by the Supreme Court and Congress in the 1990s significantly narrowed the ability of state prisoners to obtain federal writs of habeas corpus. Feder…
A critical feature of federal courts overseeing state court decisions in criminal cases is the requirement of "exhaustion." The requirement means a person must have pursued all claims related to a case in one court before pursuing them in another. The interests of "comity" and federalism play significant roles in requiring exhaustion of all potential state remedies before federal involvement. Comi…
In June of 1991, 15-year-old Laurie Show had a brief romantic involvement with Lawrence "Butch" Yunkin, the boyfriend of Lisa Lambert. Lambert, an 18-year-old resident of rural Pennsylvania, accosted Show on several occasions regarding the relationship. On 20 December 1991, Show was brutally murdered at her home, her throat slashed. Authorities arrested Lambert, six months pregnant with Yunkin's c…
Both Lambert and Blackwell agreed that Lambert was raising new issues not addressed in the state courts. However, Lambert contended a federal court could issue writs when "extraordinary circumstances are present." Federal Circuit Judge Mansmann, writing the decision, found such circumstances were not adequately defined in case law and, thus, not a valid defense. Consequently, Mansmann wrote that u…
Following the decision, Lambert appealed to the U.S. Supreme Court and requested an emergency release pending the Court's action. In early August of 1998, Justice David H. Souter denied her request for release. Later in August, a Pennsylvania court rejected Lambert's appeal. The judge wrote that Lambert "was the only person with the level of emotion [needed] . . . to have performed that dreadful a…
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