Lambert v. Blackwell

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 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 a federal 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 supremacy prevailed 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 high degree 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 under the changing habeas corpus system was still being defined as the twentieth century drew to a close.