John E. Wetzel, Secretary, Pennsylvania Department of Corrections, et al., Petitioners v. James Lambert (565 U.S. 520)
U.S. Supreme Court · decided February 21, 2012 · Supreme Court Database (Spaeth)
- Citation
- 565 U.S. 520 · 132 S. Ct. 1195
- Decided
- February 21, 2012
- Term
- October Term 2011
- Vote
- 6–3
- Issue area
- Criminal Procedure
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Per Curiam. James Lambert was convicted and sentenced to death in 1984 for the murder of two patrons during a robbery of Prince's Lounge in Philadelphia, Pennsylvania. One of the Commonwealth’s primary witnesses at Lambert’s trial was Bernard Jackson, who admitted to being involved in the robbery and identified Bruce Reese and Lambert as his accomplices. Almost 20 years later, Lambert brought a claim for postconviction relief in Pennsylvania state court, alleging that the Commonwealth had failed to disclose, inter alia, a “police activity sheet” in violation of Brady v. Maryland, 373 U. S. 83 (1963). This document, dated October 25, 1982, noted that a photo display containing a picture of an individual named Lawrence Woodlock was shown to two witnesses to the Prince’s Lounge robbery, but that “[n]o identification was made.” Exh. 1, App. to Brief in Opposition. The document further noted that “Mr. WOODLOCK is named as co-defendant” by Jackson, who was in custody at the time on several charges and had admitted to involvement in at least 13 armed robberies of bars. Ibid. The activity sheet did not indicate whether Jackson’s reference was to the Prince’s Lounge crime or one of the others. The sheet bore the names of the law enforcement officers involved in the investigation of the Prince’s Lounge robbery. It also bore the names of the robbery’s murder victims, as well as the…
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