RESPONDENT: James Lambert
LOCATION: Formerly Prince’s Lounge
DOCKET NO.: 11-38
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Third Circuit
CITATION: 565 US (2012)
GRANTED: Feb 21, 2012
DECIDED: Feb 21, 2012
Facts of the case
Bruce Reese and Bernard Jackson were brothers-in-law who had committed several robberies together in the past; James Lambert was a newcomer to the group. On September 23, 1982, they agreed to rob a bar in Philadelphia, eventually settling on Prince's Lounge. During the robbery, one man walked to the rear bar and pointed a gun in the face of a barmaid, Janet Ryan. A different man instructed another barmaid, Sarah Clark, to "get the money." While Clark was placing money in a bag, she heard two gunshots from the back of the bar; a single actor had shot and killed two patrons.
Two weeks later, Jackson identified Lambert and Reese while in custody for an unrelated robbery. Lambert and Reese were tried jointly, with Jackson testifying against them. Janet Ryan also testified, and was at first unable to identify Lambert; shortly after stepping down from the stand, however, she approached the prosecutor and indicated that Lambert was the man who pointed the gun in her face. No other witness was able to identify Lambert or Reese, but the jury found Lambert guilty of two counts of first-degree murder, robbery, criminal conspiracy, and possession of an instrument of crime. He was sentenced to death.
A few months later, the Federal Capital Habeas Corpus Unit of the Federal Defender Association of Philadelphia seized the police investigatory file in what was later ruled to be an abuse of subpoena power. Lambert's lawyers declared that several seized documents should have been available to the defense at trial, filing a claim under Pennsylvania's Post Conviction Relief Act. One document indicated that Jackson named a "Lawrence Woodlock" as a co-defendant. The district court denied this claim, concluding that there was no reasonable likelihood the disclosure would have changed the verdict. The Pennsylvania Supreme Court affirmed, holding that the additional evidence was not significant because the defense had already thoroughly impeached Jackson's testimony. The United States Court of Appeals for the Third Circuit reversed, reasoning that Jackson's statement about an additional co-defendant opened up an entirely new line of impeachment.
Did the Third Circuit properly apply the habeas deference standard to the state courts' rejection of Lambert's claim?