Wetzel v. Lambert (2011)
- Docket
- 11-38
- Decided
- 2011-01-01
Summary
Question: Did the Third Circuit properly apply the habeas deference standard to the state courts' rejection of Lambert's claim? Conclusion: No. In a per curiam opinion, the Court held that the Third Circuit improperly rejected the state courts' reasonable conclusion about the contents of the document. It cited the Antiterrorism and Effective Death Penalty Act of 1996, which precluded a federal court from granting a writ of habeas corpus to a state prisoner unless the adjudication of his claim by state courts involved an unreasonable application of federal law. The Court argued that the Third Circuit overlooked the determination of the state courts that the documents were entirely ambiguous; instead, the Third Circuit focused solely on the state courts' statements on the impeachment value of the evidence. The Court noted that the document did not explicitly link Woodlock to the Prince's Lounge robbery, that Jackson committed a dozen or so similar robberies, that Jackson was being held on several charges while the document was prepared, that Woodlock's name didn't appear anywhere else in the evidence, and that the two barmaids did not verify Woodlock's involvement. Justice Stephen Breyer dissented, joined by Justices Ruth Bader Ginsburg and Elena Kagan. He disputed the majority's notion that the document was entirely ambiguous, and moreover argued that the state courts did not arrive at that conclusion at all. Instead, Justice Breyer pointed out that the Pennsylvania Supreme Court was merely quoting the state's argument, not agreeing with it. He would have denied the petition for a writ of certiorari because the question was a fact-specific determination applying well-established legal principles.