Lambert v. Blackwell

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 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 murder and 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. Not only did she carry her previous claims forward, but also added new ones including "actual innocence" of the murder and police misconduct. Lambert alleged a 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 because she 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 to the U.S. Attorney General for possible legal action against state prosecutors and police. Pennsylvania immediately appealed to the federal court of appeals.