Appellant
Lisa Michelle Lambert
Appellee
Charlotte Blackwell and the State of Pennsylvania
Appellant's Claim
That she should be granted habeas corpus and should be allowed to claim innocence from having committed the murder for which she was convicted.
Chief Lawyer for Appellant
Peter S. Greenberg
Chief Lawyer for Appellee
Richard A. Sprague
Justices for the Court
Arthur L. Alarcon, Morton Greenberg, Carol Mansmann (writing for the court)
Justices Dissenting
None
Place
Lancaster, Pennsylvania
Date of Decision
29 December 1997
Decision
Ruled against Lambert, returning her to prison.
Significance
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. Federal courts would not accept petitions if any unresolved aspects to the case existed in state courts. Claims simply of innocence, even based on new evidence, were not enough. Advocates for the protectionof individual constitutional rights were concerned with the treatment that individuals would receive from states given fewer federal checks.
Writ means court order and habeas corpus comes from Latin meaning "youhave the body." A writ of habeas corpus is therefore a court order directing someone, such as a prison warden, to produce a prisoner at a specificplace and time. The court may then determine the legality of the detainment.The habeas corpus writ provides a powerful means to correct legal errors by releasing prisoners after convictions even where all procedural safeguards and appeals had been applied. The prisoner holds responsibility to initiate the writ process by submitting to the court a petition explaining how their imprisonment violates a constitutional right.
Such writs have a long history in English common law, first used by English courts to question detentions by feudal lords. The writ of habeas corpus is addressed briefly in Article I of the U.S. Constitution recognizing itsimportant role except "in Cases of Rebellion or Invasion" for purposes of "public Safety." As such, President Abraham Lincoln suspended habeas corpus writs during the Civil War.
Use of the habeas corpus writ began expanding in the latter 19th century. The Habeas Corpus Act of 1867 extended authority of federal courts to issue writs for any person detained, including state prisoners. Beginning with Brown v. Allen (1953), a series of Court rulings further expanded habeas corpus law into the realm of civil rights protection. In 1963 the Court ruled in Fay v. Noia that prisoner access to federal review was itself a fundamental right, and in Townsend v. Sain the Court ruled thatfederal judges should not defer to state judge's findings but apply federallaw independently.
Comity and Exhaustion
A critical feature of federal courts overseeing state court decisions in criminal cases is the requirement of "exhaustion." The requirement means a personmust have pursued all claims related to a case in one court before pursuingthem in another. The interests of "comity" and federalism play significant roles in requiring exhaustion of all potential state remedies before federal involvement. Comity means one court should not act within its jurisdiction until another court with similar powers and already involved in the case has an opportunity to fully rule on the matter. This means state courts should also have the opportunity to respond to allegations they erred before federal courts become involved. Federalism essentially refers to the division of powers between federal and state governments, and the degree of freedom that states have from federal control. That degree has varied through time based on prevailing theories. The Court held in Frisbie v. Collins (1952) that only incases of "special circumstances" should a federal court accept a case with unexhausted claims. However, the Court did not offer examples of such circumstances, leaving much uncertainty.
Given these principles, federal courts only issued writs for petitions alleging substantial constitutional violations. The Due Process Clause of the Fifthand Fourteenth Amendments were commonly the basis for petitions, including claims of prosecutorial misconduct and ineffective assistance of legal counsel. Often, in such situations the prisoner was allowed an evidentiary hearing to review their evidence.
Public pressure from victims' rights advocates and others seeking swifter criminal proceedings mounted through the 1970s. A transformation of the SupremeCourt toward dramatically decreasing the amount of federal court involvementin state judicial proceedings began with Wainwright v. Sykes (1977). Central to related debates were arguments about the appropriate role of federal court jurisdiction in a system based on federalism. Eventually, use of federal habeas corpus writs was substantially narrowed by the 1990s. In Herrera v. Collins (1993) the Court held that claims of "actual innocence" were insufficient to justify writs. Newly discovered evidence was no longer enough by itself.
In the mid-1990s the ruling in Schlup v. Delo (1995) and the passage of the Anti-Terrorism and Effective Death Penalty Act (AEDPA) of 1996 broughteven tougher standards to the habeas corpus appeals process. Prisonerschallenging their convictions were required to show "clear and convincing" evidence for courts to accept their petitions, a considerably more difficult standard. The act more clearly required exhaustion of all claims at the statelevel before a federal judge could consider issuing a writ. All claims in a federal habeas corpus petition must have been previously presented to state courts for action. Such a requirement avoided "piecemeal" litigation byforcing all claims to be decided in a single proceeding. The exhaustion requirement could be waived if no actual state process existed for a particular case, or if it was proven that the state could not effectively protect a petitioner's rights.
A Teenage Love Triangle
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 herhome, her throat slashed. Authorities arrested Lambert, six months pregnantwith Yunkin's child, and her friend Tabitha Buck on homicide charges. Buck was convicted of second degree murder and sentenced to life in prison. Yunkin pled guilty to hindering apprehension by assisting the two after the murder and received 10 to 20 years in prison. In July of 1992 the Court of Common Pleas of Lancaster County, Pennsylvania, convicted Lambert of first-degree murderand sentenced her to life in prison.
Following conviction, Lambert raised various allegations of trial error and misconduct by the state prosecutor but the court denied her motions. Lambert next filed a motion for a retrial based on new evidence from Yunkin's later testimony in other court proceedings. She also claimed ineffective lawyer assistance in her original trial for failure to present various forms of crucial evidence. In March of 1995 a Pennsylvania state court denied Lambert's motion.The Superior Court of Pennsylvania also denied her later appeal in January of 1996 as did the Pennsylvania Supreme Court in July of 1996.
Lambert next filed a federal habeas corpus petition in September of 1996 with the U.S. District Court of the Eastern District of Pennsylvania. Notonly did she carry her previous claims forward, but also added new ones including "actual innocence" of the murder and police misconduct. Lambert allegeda massive effort by police and prosecutors to frame her for the murder. The state responded that Lambert's case was not entitled to federal review becauseshe had not exhausted state court remedies for the newer claims. Despite state arguments, the court decided to conduct an evidentiary hearing on the claims of innocence and prosecutorial misconduct because of the case's "highly unusual circumstances." After two weeks of hearings, the district court found in April of 1997 that a recent amendment to Pennsylvania criminal law had effectively eliminated any means for Lambert to contest her conviction in state courts. Therefore, all possible state remedies were exhausted. The court issued the writ, released Lambert from custody, and prohibited Pennsylvania from holding a retrial since the state could not be trusted in this case. The federal judge found that the case was filled with police perjury, witness tampering, fabricated evidence, and suppression of evidence by the state prosecutor leading to "a manifestly unjust incarceration." The judge sent his opinion tothe U.S. Attorney General for possible legal action against state prosecutorsand police. Pennsylvania immediately appealed to the federal court of appeals.
Back to Prison
Both Lambert and Blackwell agreed that Lambert was raising new issues not addressed in the state courts. However, Lambert contended a federal court couldissue 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 unlike the district court the appeals court could not so quickly pass over Lambert's claims of exhaustion and "must consider whether Lambertis required to present her unexhausted claims to the Pennsylvania courts." Mansmann found Lambert's extensive claims "present unresolved questions of fact and of state law and, thus, the interests of comity and justice are betterserved by requiring complete exhaustion" by Pennsylvania courts. Mansmann found no authority for the district court to waive the exhaustion requirement since Pennsylvania had not requested such a waiver as required in the revised AEDPA.
Mansmann wrote the assessment of Lambert's "actual innocence" claim was unnecessary. Such an examination, also prohibited under AEDPA, would "deprive thestate courts of an opportunity to correct their own errors, if any." Mansmannreversed the district court's not guilty verdict and reinstated her life sentence. Lambert's ten months of freedom came to an end. Mansmann ordered the district court to dismiss the writ petition and allow Lambert to pursue her unexhausted claims in the appropriate Pennsylvania state court.
Impact
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 performedthat dreadful act."
Lambert revealed how extreme an "actual innocence" claim must be to obtain a writ of habeas corpus under the AEDPA. The case also marked a rare occasion in which a person convicted of murder was ordered released by afederal judge without returning the case to state courts. Some asserted the writ standard had become too tough for petitioners to prove errors--that if actually proven, such extensive misconduct might warrant prosecution as attempted murder by wrongfully seeking death penalties for the accused.
Lambert also highlighted the larger debate over federalism in the U.S.legal system. During the Warren Court era, a doctrine of national supremacyprevailed in which the federal courts held expansive powers over review of state actions, including state court decisions. By the 1990s the alternate theory of federalism, dual sovereignty, again prevailed where states held a highdegree of independence over such issues as health, education, and criminal justice. By the late 1990s, many were concerned over how fair and consistent state judges, less susceptible to federal oversight, would apply review procedures. The Court and Congress had substantially limited the ability of state prisoners to seek review of alleged civil rights violations outside the state court systems that originally convicted them. The role of federal courts underthe changing habeas corpus system was still being defined as the twentieth century drew to a close.
Related Cases
Lisa Michelle Lambert
Appellee
Charlotte Blackwell and the State of Pennsylvania
Appellant's Claim
That she should be granted habeas corpus and should be allowed to claim innocence from having committed the murder for which she was convicted.
Chief Lawyer for Appellant
Peter S. Greenberg
Chief Lawyer for Appellee
Richard A. Sprague
Justices for the Court
Arthur L. Alarcon, Morton Greenberg, Carol Mansmann (writing for the court)
Justices Dissenting
None
Place
Lancaster, Pennsylvania
Date of Decision
29 December 1997
Decision
Ruled against Lambert, returning her to prison.
Significance
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. Federal courts would not accept petitions if any unresolved aspects to the case existed in state courts. Claims simply of innocence, even based on new evidence, were not enough. Advocates for the protectionof individual constitutional rights were concerned with the treatment that individuals would receive from states given fewer federal checks.
Writ means court order and habeas corpus comes from Latin meaning "youhave the body." A writ of habeas corpus is therefore a court order directing someone, such as a prison warden, to produce a prisoner at a specificplace and time. The court may then determine the legality of the detainment.The habeas corpus writ provides a powerful means to correct legal errors by releasing prisoners after convictions even where all procedural safeguards and appeals had been applied. The prisoner holds responsibility to initiate the writ process by submitting to the court a petition explaining how their imprisonment violates a constitutional right.
Such writs have a long history in English common law, first used by English courts to question detentions by feudal lords. The writ of habeas corpus is addressed briefly in Article I of the U.S. Constitution recognizing itsimportant role except "in Cases of Rebellion or Invasion" for purposes of "public Safety." As such, President Abraham Lincoln suspended habeas corpus writs during the Civil War.
Use of the habeas corpus writ began expanding in the latter 19th century. The Habeas Corpus Act of 1867 extended authority of federal courts to issue writs for any person detained, including state prisoners. Beginning with Brown v. Allen (1953), a series of Court rulings further expanded habeas corpus law into the realm of civil rights protection. In 1963 the Court ruled in Fay v. Noia that prisoner access to federal review was itself a fundamental right, and in Townsend v. Sain the Court ruled thatfederal judges should not defer to state judge's findings but apply federallaw independently.
Comity and Exhaustion
A critical feature of federal courts overseeing state court decisions in criminal cases is the requirement of "exhaustion." The requirement means a personmust have pursued all claims related to a case in one court before pursuingthem in another. The interests of "comity" and federalism play significant roles in requiring exhaustion of all potential state remedies before federal involvement. Comity means one court should not act within its jurisdiction until another court with similar powers and already involved in the case has an opportunity to fully rule on the matter. This means state courts should also have the opportunity to respond to allegations they erred before federal courts become involved. Federalism essentially refers to the division of powers between federal and state governments, and the degree of freedom that states have from federal control. That degree has varied through time based on prevailing theories. The Court held in Frisbie v. Collins (1952) that only incases of "special circumstances" should a federal court accept a case with unexhausted claims. However, the Court did not offer examples of such circumstances, leaving much uncertainty.
Given these principles, federal courts only issued writs for petitions alleging substantial constitutional violations. The Due Process Clause of the Fifthand Fourteenth Amendments were commonly the basis for petitions, including claims of prosecutorial misconduct and ineffective assistance of legal counsel. Often, in such situations the prisoner was allowed an evidentiary hearing to review their evidence.
Public pressure from victims' rights advocates and others seeking swifter criminal proceedings mounted through the 1970s. A transformation of the SupremeCourt toward dramatically decreasing the amount of federal court involvementin state judicial proceedings began with Wainwright v. Sykes (1977). Central to related debates were arguments about the appropriate role of federal court jurisdiction in a system based on federalism. Eventually, use of federal habeas corpus writs was substantially narrowed by the 1990s. In Herrera v. Collins (1993) the Court held that claims of "actual innocence" were insufficient to justify writs. Newly discovered evidence was no longer enough by itself.
In the mid-1990s the ruling in Schlup v. Delo (1995) and the passage of the Anti-Terrorism and Effective Death Penalty Act (AEDPA) of 1996 broughteven tougher standards to the habeas corpus appeals process. Prisonerschallenging their convictions were required to show "clear and convincing" evidence for courts to accept their petitions, a considerably more difficult standard. The act more clearly required exhaustion of all claims at the statelevel before a federal judge could consider issuing a writ. All claims in a federal habeas corpus petition must have been previously presented to state courts for action. Such a requirement avoided "piecemeal" litigation byforcing all claims to be decided in a single proceeding. The exhaustion requirement could be waived if no actual state process existed for a particular case, or if it was proven that the state could not effectively protect a petitioner's rights.
A Teenage Love Triangle
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 herhome, her throat slashed. Authorities arrested Lambert, six months pregnantwith Yunkin's child, and her friend Tabitha Buck on homicide charges. Buck was convicted of second degree murder and sentenced to life in prison. Yunkin pled guilty to hindering apprehension by assisting the two after the murder and received 10 to 20 years in prison. In July of 1992 the Court of Common Pleas of Lancaster County, Pennsylvania, convicted Lambert of first-degree murderand sentenced her to life in prison.
Following conviction, Lambert raised various allegations of trial error and misconduct by the state prosecutor but the court denied her motions. Lambert next filed a motion for a retrial based on new evidence from Yunkin's later testimony in other court proceedings. She also claimed ineffective lawyer assistance in her original trial for failure to present various forms of crucial evidence. In March of 1995 a Pennsylvania state court denied Lambert's motion.The Superior Court of Pennsylvania also denied her later appeal in January of 1996 as did the Pennsylvania Supreme Court in July of 1996.
Lambert next filed a federal habeas corpus petition in September of 1996 with the U.S. District Court of the Eastern District of Pennsylvania. Notonly did she carry her previous claims forward, but also added new ones including "actual innocence" of the murder and police misconduct. Lambert allegeda massive effort by police and prosecutors to frame her for the murder. The state responded that Lambert's case was not entitled to federal review becauseshe had not exhausted state court remedies for the newer claims. Despite state arguments, the court decided to conduct an evidentiary hearing on the claims of innocence and prosecutorial misconduct because of the case's "highly unusual circumstances." After two weeks of hearings, the district court found in April of 1997 that a recent amendment to Pennsylvania criminal law had effectively eliminated any means for Lambert to contest her conviction in state courts. Therefore, all possible state remedies were exhausted. The court issued the writ, released Lambert from custody, and prohibited Pennsylvania from holding a retrial since the state could not be trusted in this case. The federal judge found that the case was filled with police perjury, witness tampering, fabricated evidence, and suppression of evidence by the state prosecutor leading to "a manifestly unjust incarceration." The judge sent his opinion tothe U.S. Attorney General for possible legal action against state prosecutorsand police. Pennsylvania immediately appealed to the federal court of appeals.
Back to Prison
Both Lambert and Blackwell agreed that Lambert was raising new issues not addressed in the state courts. However, Lambert contended a federal court couldissue 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 unlike the district court the appeals court could not so quickly pass over Lambert's claims of exhaustion and "must consider whether Lambertis required to present her unexhausted claims to the Pennsylvania courts." Mansmann found Lambert's extensive claims "present unresolved questions of fact and of state law and, thus, the interests of comity and justice are betterserved by requiring complete exhaustion" by Pennsylvania courts. Mansmann found no authority for the district court to waive the exhaustion requirement since Pennsylvania had not requested such a waiver as required in the revised AEDPA.
Mansmann wrote the assessment of Lambert's "actual innocence" claim was unnecessary. Such an examination, also prohibited under AEDPA, would "deprive thestate courts of an opportunity to correct their own errors, if any." Mansmannreversed the district court's not guilty verdict and reinstated her life sentence. Lambert's ten months of freedom came to an end. Mansmann ordered the district court to dismiss the writ petition and allow Lambert to pursue her unexhausted claims in the appropriate Pennsylvania state court.
Impact
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 performedthat dreadful act."
Lambert revealed how extreme an "actual innocence" claim must be to obtain a writ of habeas corpus under the AEDPA. The case also marked a rare occasion in which a person convicted of murder was ordered released by afederal judge without returning the case to state courts. Some asserted the writ standard had become too tough for petitioners to prove errors--that if actually proven, such extensive misconduct might warrant prosecution as attempted murder by wrongfully seeking death penalties for the accused.
Lambert also highlighted the larger debate over federalism in the U.S.legal system. During the Warren Court era, a doctrine of national supremacyprevailed in which the federal courts held expansive powers over review of state actions, including state court decisions. By the 1990s the alternate theory of federalism, dual sovereignty, again prevailed where states held a highdegree of independence over such issues as health, education, and criminal justice. By the late 1990s, many were concerned over how fair and consistent state judges, less susceptible to federal oversight, would apply review procedures. The Court and Congress had substantially limited the ability of state prisoners to seek review of alleged civil rights violations outside the state court systems that originally convicted them. The role of federal courts underthe changing habeas corpus system was still being defined as the twentieth century drew to a close.
Related Cases
- Frisbie v. Collins, 342 U.S. 519 (1952).
- Brown v. Allen, 344 U.S. 443 (1953).
- Townsend v. Sain, 372 U.S. 293 (1963).
- Fay v. Noia, 372 U.S. 391 (1963).
- Wainwright v. Sykes, 433 U.S. 72 (1977).
- Herrera v. Collins, 113 S. Ct. 853 (1993).
- Schlup v. Delo, 513 U.S. 298 (1995).
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