Wetzel v. Lambert, 132 S. Ct. 1195

Lambert was convicted and sentenced to death in 1984 for murders committed during a Prince's Lounge robbery in Philadelphia.
Key Commonwealth witness Bernard Jackson admitted involvement in multiple robberies and identified Lambert and Reese as participants.
Nearly two decades later Lambert sought postconviction relief alleging Brady violations for failure to disclose a police activity sheet from 1982.
The activity sheet described a photo display shown to two witnesses; it listed a Lawrence Woodlock, with note that no identification was made and that Woodlock was named as a co-defendant by Jackson in some incident.
The sheet did not specify whether Woodlock’s involvement was in the Prince's Lounge robbery or another robbery; Woodlock’s name appeared nowhere else in Prince's Lounge files.
Pennsylvania courts held the sheet not material, and the state Supreme Court rejected Lambert’s Brady claim as lacking reasonable probability of a different trial outcome; Lambert then challenged via 28 U.S.C. § 2254.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the police activity sheet Brady material?	Lambert contends the sheet is exculpatory/impeaching evidence.	Lambert's claim is outweighed by ambiguity; Woodlock’s co-defendant reference is not tied to this robbery.	No Brady violation found by state courts; later federal review questioned AEDPA standard.
Did the notations provide impeachment material beyond cumulative evidence?	Lambert argues it would impeach Jackson beyond prior impeachment.	The state court deemed impeachment from the sheet cumulative and not material.	State court deemed not material; AEDPA review disputed by Third Circuit but not here.
Did AEDPA preclude federal relief given the state court’s reasoning?	Lambert argues the state court’s decision was unreasonable under AEDPA.	Commonwealth asserts the state court’s reasoning was reasonable.	Court unanimously grants cert and remands; focus on whether reasonable under AEDPA.
Did the Third Circuit reasonably apply applicable law in denying relief?	Lambert claims not addressed ambiguity and potential impeachment value.	Third Circuit focused on cumulativeness and did not overrule ambiguity.	Court remands; vacates Third Circuit judgment for proceedings consistent with the opinion.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (due process requires disclosure of favorable evidence)
Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (materiality standard for suppressed evidence in capital cases)
Harrington v. Richter, 562 U.S. 86 (U.S. 2011) (AEDPA deference framework for state-court decisions)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (prosecutor's duty to disclose favorable evidence; materiality)