Wetzel v. Lambert: Another US Supreme Court Decision on the Frustrating AEDPA

Many have come to know about the AEDPA (Anti-terrorism and Effective Death Penalty Act of 1996 ) because of the Troy Davis case (read our earlier post here).  The AEDPA, however, impacts many, many capital punishment cases here in the United States, since it ties the hands of federal court judges to act in reviewing death penalty cases coming out of state courts. 

What the AEDPA Does

What the AEDPA does is limit the ability or power of habeas corpus laws.  For many, this translates to risking innocent men and women being executed in this country. 

This month, another AEDPA ruling has come down from the United States Supreme Court.  The matter involved the highest court in the country reviewing the determinations of the highest court for the State of Pennyslvania as well as the U.S. Third Circuit Court of Appeals.

The Story of Wetzel v Lambert

The case of Wetzel v Lambert was decided by the U.S. Supreme Court per curiam on February 21, 2012, with three justices dissenting (Breyer; Ginsburg; Kagan).  You can read the opinion and follow its aftermath here. 

Here's the backstory:  in Pennsylvania back in 1984, a man named James Lambert was convicted and sentenced to death for the murder of two bar patrons during a robbery of a place called Prince's Lounge in Philadelphia.  At the murder trial, one of the robbers took the stand for the prosecution and pointed the finger at Mr. Lambert along with another man, Bruce Reese, as being in cahoots with him in robbing the bar. 

Lambert is convicted, the death penalty is imposed, and the appellate process begins.  Twenty years later, Lambert's attorneys advance an argument that error has occurred because the prosecution never disclosed to the defense at trial of the "police activity sheet."  It's a big deal. 

If the state attorneys had done this, then this would fly in the face of longstanding Supreme Court precedent, Brady v. Maryland, 373 U. S. 83 (1963). 

What's in the "police activity sheet"?  In that sheet, a photo of a man named Lawrence Woodlock was shown to two people who were at the bar during the robbery.  Woodlock was named as a co-defendant by the state attorneys on the sheet in the Prince's Lounge robbery.  Woodlock had a record of over 13 armed robberies of bars.  Woodlock was already in custody at the time of trial on other charges.

It also had the names of two police investigators in the Lambert case and the names of those who died during the robbery with their corresponding case numbers.  Finally, it had Jackson - Lambert's buddy who took the stand against him - as stating that Woodlock had been involved in the Prince's Lounge job. 

For all these years, much less during the trial, the Commonwealth of Pennsylvania had not notified the defense of this document much less provided it to Lambert.  Lambert's counsel was never notified that known armed robber Larry Woodlock had ever been investigated, or had his photo shown to a Prince's Lounge witness. 

Why did this matter now?

It matters because if that police activity sheet were available at trial, Lambert's attorneys could have argued that someone other than Lambert committed the armed robbery at Prince's Lounge - or that there were more people involved in the robbery that the state had been suggesting. 

Additionally, Lambert argued that his trial counsel could have used the sheet in their examination of the finger-pointing Jackson when he was on the witness stand.  Why wasn't Jackson mentioning Woodlock in his trial testimony? 

In sum, the police document is argued to be "exculpatory evidence" under federal law and accordingly, pursuant to Brady v. Maryland, the state prosecutor must provide material exculpatory information that it has in its possession, custody, or control to the defense attorneys.

How the AEDPA Comes In - Frustrations of the Federal Courts

The AEDPA limits the power of the federal courts - even the United States Supreme Court (outside of de novo cert) - to review state court decisions.   Federal appellate courts, faced with clear injustice and with hands tied by the AEDPA, will push the edge of the envelope to try and do the right thing - particularly when a death penalty case comes before them.

However, the United States Supreme Court writes in Wetzel that this is "overreaching" that "...continues to occupy an undue portion of the Supreme Court's docket."

What Happens Now in Wetzel v. Lambert

On this issue of the unshared police document, the Pennsylvania Supreme Court unanimously decided in favor of the state attorneys:  (1) the ambiguous notation on a police activity sheet regarding a suspect's identification of a "co-defendant" was not material and (2) using the sheet to impeach Jackson's testimony would have been cumulative, no big addition to the case.

The issue was then taken to the federal courts, since the state high court had ruled and state remedies were exhausted.  The Federal District Court agreed with the Pennsylvania Supreme Court.   Habeas request denied. 

The Third Circuit Court of Appeals did not.  It found that the state court's second ground for its decision,  the cumulative nature of the impeachment, was unreasonable.  The appellate court did not voice an opinion on the other ground.  

The United States Supreme Court has now found that the Third Circuit Court of Appeals has to rule on both grounds, and has sent the case back to the lower federal appellate court for additional work.  With its reversal, this caveat:

Any retrial here would take place three decades after the crime, posing the most daunting difficulties for the prosecution. That burden should not be imposed unless each ground supporting the state court decision is examined and found to be unreasonable under AEDPA.  

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