Supreme Court Decides Wetzel v. Lambert
On February 21, 2012, the Supreme Court decided Wetzel v. Lambert, No. 11-38, holding that a court should not grant habeas relief under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) unless each ground supporting the state court decision is examined and found to be unreasonable under AEDPA.
Lambert was convicted and sentenced to death in 1984 for the murder of two patrons during a robbery of a bar. Twenty years later, Lambert sought relief based on the discovery of a previously undisclosed police activity sheet that referred to a witness's failure to identify a picture of Lambert. Lambert claimed that the sheet was exculpatory and that the government's failure to disclose it violated his rights under Brady v. Maryland, 373 U.S. 83 (1963). The government claimed that the sheet was at best ambiguous and that the notation in question referred to a different robbery. The Pennsylvania Supreme Court denied Lambert relief, and a federal district court denied federal habeas corpus relief. The Third Circuit reversed on the ground that the sheet would have permitted Lambert to pursue an entirely new line of impeachment.
The Supreme Court reversed, quoting the AEDPA language precluding the grant of a writ of habeas corpus to a state prisoner unless the state adjudication of the claim "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established federal law" as determined by the Supreme Court. The Court held that the Third Circuit had focused entirely on the state court's finding that any impeachment value would have been cumulative, overlooking its alternative state court finding that the notations at issue were "entirely ambiguous." Because the circuit court did not examine whether that alternative ground might have been "reasonable" under the AEDPA, the court erred in granting relief. The Court remanded the case for further proceedings consistent with its decision.
The Court delivered its decision per curiam. Justice Breyer filed a dissenting opinion, in which Justices Ginsburg and Kagan joined.
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