Lambert v. Blackwell

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 unlike the district court the appeals court could not so quickly pass over Lambert's claims of exhaustion and "must consider whether Lambert is 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 better served 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 the state courts of an opportunity to correct their own errors, if any." Mansmann reversed 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.