Lambert v. Beard
2011 U.S. App. LEXIS 2333
3rd Cir.2011Background
- Lambert was convicted of two counts of first-degree murder and other charges, sentenced to death, after a 1984 trial in Pennsylvania.
- The Commonwealth relied on statements by Bernard Jackson, a cooperating witness who testified after pleading to related crimes.
- Jackson provided multiple inconsistent statements over time, and the defense impeached him at trial; the Commonwealth allegedly withheld a Police Activity Sheet naming a potential third participant.
- Lambert filed multiple PCRA petitions and a federal habeas petition; the district court denied relief on most claims but granted a COA on Brady and Mills-related issues.
- On appeal, the Third Circuit held that the state court's Brady ruling was unreasonable in light of Napue/Brady doctrine, and vacated the district court's judgment to remand for conditional habeas relief.
- The panel directed that Lambert be retried within 120 days, with release if the Commonwealth failed to retry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the Police Activity Sheet Brady material? | Lambert argues sheet was material for impeachment and credibility. | Commonwealth contends impeachment was cumulative and materiality lacking. | Yes; withholding was material and unreasonable application of Brady. |
| Did failure to disclose the co-defendant reference undermine due process? | Lambert contends hidden co-defendant detail could have altered the trial's outcome. | Commonwealth asserts existing impeachment sufficed; disclosure would be cumulative. | Yes; non-disclosure created a reasonable probability of different result. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (constitutional duty to disclose favorable evidence)
- Giglio v. United States, 405 U.S. 150 (U.S. 1972) (impeachment evidence may be material)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (materiality and reasonable probability standard)
- Napue v. Illinois, 360 U.S. 264 (U.S. 1959) (knowing false testimony requires reversal; extends to Brady context)
- Banks v. Dretke, 540 U.S. 668 (U.S. 2004) (impeachment evidence's effect on materiality when informant status disclosed)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (probative value of withheld evidence assessed in context of total evidence)
- Harrington v. Richter, U.S. _, 131 S. Ct. 770 (U.S. 2011) (unreasonable application standard for AEDPA review)
- United States v. Perdomo, 929 F.2d 967 (3d Cir. 1991) (non-cumulative impeachment evidence can be material)