Lambert v. Blackwell

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 protection of 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 "you have 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 specific place 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 its important 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 that federal judges should not defer to state judge's findings but apply federal law independently.