Lambert v. Blackwell, NO. 01-CV-2511 (E.D. Pa. 4/1/2003)
| Decision Date | 01 April 2003 |
| Docket Number | NO. 01-CV-2511.,01-CV-2511. |
| Parties | LISA MICHELLE LAMBERT, Petitioner, v. MRS. CHARLOTTE BLACKWELL, SUPT., et. al., Respondents. |
| Court | U.S. District Court — Eastern District of Pennsylvania |
I am aware of the human tragedy that rests at the core of this litigation. The narrative before me begins with abuse and jealousy and ends with shattered lives. It is about the victim, Laurie Show, whose murder at age 15 left her parents childless. It is also about the defendant, Lisa Michelle Lambert, who entered prison at age 18 with a life sentence and no possibility of parole. Although tragic, these facts cannot, and do not, alter my judicial responsibilities: Congress has narrowly defined and circumscribed my role in this litigation.
The contentious history of this case could also overshadow the laws that govern both the case and my role as a United States District Court judge. For this reason, I will briefly describe the role of a federal district court judge in reviewing state court criminal convictions and the impact of state court decisions on my review of an application for a writ of habeas corpus.1 Because Lisa Michelle Lambert's case began with her conviction in state court, before addressing the scope and nature of federal habeas corpus review, I will describe the procedure for handling criminal cases in the Pennsylvania state courts.
Ordinarily, the states, not the federal government, have the power to enact and enforce the laws that relate to homicide. This explains why the district attorney of Lancaster County, Pennsylvania, an offshoot of the state prosecutor's office, brought the charge of homicide against Lisa Michelle Lambert and why the Honorable Lawrence F. Stengel, a judge of the Commonwealth of Pennsylvania sitting in Lancaster county, tried and sentenced her. In Pennsylvania, all direct appeals from a guilty verdict in a criminal case are presented to the Pennsylvania Superior Court, which has a duty to hear all such appeals. A defendant may also ask the state's highest court, the Pennsylvania Supreme Court, to review an adverse decision of the Pennsylvania Superior Court. However, the Pennsylvania Supreme Court, unlike the Pennsylvania Superior Court, is not required to hear all appeals. That is, it may refuse to hear the appeal. Whether the Pennsylvania Supreme Court hears the case or refuses to hear the case, a criminal defendant may request review before the United States Supreme Court. Such review is rarely granted.
In addition to appealing directly to the Pennsylvania Superior Court and the Pennsylvania Supreme Court, a criminal defendant in Pennsylvania can seek state court relief through a petition for collateral review of his or her conviction. Under the Pennsylvania Post Conviction Relief Act (the "PCRA"), a convicted defendant who has appealed his or her conviction to the Pennsylvania Superior Court, and has been unsuccessful, can also file a petition with the trial court (the "PCRA court") seeking a new trial or an acquittal based on, among other things, violations of the Constitution of the Commonwealth of Pennsylvania or the Constitution or laws of the United States that undermined the reliability of the conviction. A petitioner may appeal a denial of a PCRA petition to the Pennsylvania Superior Court and the Pennsylvania Supreme Court.
It is only after a defendant in state court has exhausted his or her state remedies — direct appeal and collateral challenges under the PCRA — in the state courts that he or she can petition for habeas corpus relief in the federal courts. To apply to the United States District Court for a writ of habeas corpus, a petitioner must assert that the petitioner's conviction violated the United States Constitution. If a petitioner fails to allege a constitutional violation, the federal court must deny his or her habeas petition. The alleged errors raised in the federal habeas proceeding must be the same as those errors previously presented to the state courts. If a defendant fails to present the alleged error during direct or collateral review, his or her habeas petition will be "procedurally defaulted" as to that claim. Procedural default will be excused only where the petitioner establishes either "cause and prejudice" for the default or that he or she is "actually innocent" of the crime.
It is against this procedural background that Congress passed and President Clinton signed the Antiterrorism and Effective Death Penalty Act of 1996 (the "AEDPA"). This legislation amended federal habeas law by further narrowing the availability of federal habeas corpus relief. For example, the AEDPA imposes a strict statute of limitations period for filing habeas petitions as well as restrictions on successive petitions. While federal habeas law always incorporated concepts of comity, that is respect for state courts, into its jurisprudence, the AEDPA required increased deference by federal judges to state courts' factual findings and legal conclusions. Thus, under the AEDPA the federal court must uphold a state court ruling unless the state court decision was "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States," or "was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." 28 U.S.C. § 2254(d)(1)-(2). As Justice Stevens observed of federal habeas practice generally, and the AEDPA specifically, "it seems clear that Congress intended federal judges to attend with the utmost care to state-court decisions, including all of the reasons supporting their decisions, before concluding that those proceedings were infected by constitutional error sufficiently serious to warrant the issuance of the writ." Terry Williams v. Taylor, 529 U.S. 362, 386, 120 S.Ct. 1495 (2000).
As Terry Williams points out, under the AEDPA a federal judge has a limited role in evaluating habeas petitions filed by individuals convicted in state court. These limitations are both procedural and substantive in nature. The procedural limitations stem from the requirement that a federal habeas petitioner contest his or her conviction through a series of state court appeals and that he or she present any allegation of constitutional error to a PCRA court. The substantive limitations arise from the federal court's restricted ability to make findings contrary to those expressed in earlier state court decisions. The role of the federal court, under the AEDPA, is highly restrictive: The court's task is to evaluate only those claims of constitutional error previously litigated in state court, or those claims which excuse procedural default, and this evaluation is to be performed with great deference to the state court's factual findings and legal conclusions.
Lisa Michelle Lambert was tried and convicted in a Pennsylvania state court. Adjudication of her federal habeas petition is subject to the AEDPA and the limitations described above. Thus, I must first consider the threshold issue whether the AEDPA's procedural requirements bar review of Lambert's petition. Resolution of this issue requires deciding whether Lambert has complied with the AEDPA's conditions and deadlines for filing a federal habeas petition. Lambert has satisfied these requirements. I will therefore examine the merits of her petition. After reviewing and analyzing the legal and factual determinations of the Pennsylvania state courts in this light, I find that Lambert has failed to satisfy the AEDPA's exacting standard for overturning a state court conviction. Therefore, I will deny her petition.2
December 20, 1991 Lisa Michelle Lambert ("Lambert") is charged with first degree murder and conspiracy to commit murder in the death of Laurie Show.
July 27, 1992 The Honorable Lawrence F. Stengel of the Lancaster County Court of Common Pleas finds Lambert guilty of first degree murder and conspiracy to commit murder. Lambert is represented at trial by Roy D. Shirk, Esq. and Alan G. Goldberg, Esq.
July 28, 1992 Lambert files her first set of post-trial motions, claiming that the trial court erred by:
(a) Denying Lambert's motion for change of venue and/or venire.
(b) Denying Lambert's motion for sanctions.
(c) Denying Lambert's motion and allowing into evidence the statement of Tabitha Buck.
(d) Allowing the trier of fact to take notes during testimony at trial and to use the noted during deliberation.
(e) Affirming and reading the Commonwealth's number 3 and 4 of the Commonwealth's Points for Charge.
(f) Denying Lambert's motion for mistrial based on not receiving supplemental discovery regarding Laura Thomas.
(g) Denying Lambert's motion for mistrial based on not receiving supplemental discovery regarding Hazel Show.
(h) Denying Lambert's motion for mistrial based on not receiving supplemental discovery regarding Richard Kleinhans.
(i) Denying Lambert's motion for mistrial based on the prosecution withholding evidence that they had knowledge that a jergo was thrown away and were informed of its location.
(j) Qualifying Dr. Enrique Penades as an expert in forensic pathology because Panades is not board certified in forensic pathology.
(k) Denying Lambert's motion for mistrial based on the prosecution withholding from discovery a portion of Yunkin's statement on February 4, 1992.
(l) Denying Lambert's motion for mistrial based on the Assistant District Attorney asking of witness Samuel J. Golub two questions he knew were beyond the expert witness' field of expertise.
(m) Sustaining a verdict of murder in the first degree and criminal conspiracy to commit criminal homicide against Lambert on the basis of insufficient evidence; the Commonwealth failed to prove the charges and the verdict was based on suspicion, conjecture, and assumption.
(n) Sustaining a verdict of murder in the first degree and...
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