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In perhaps the most closely watched murder case in Pennsylvania history, a federal appeals court has upheld the conviction of Lisa Michelle Lambert, rejecting the findings of a federal judge who had previously declared that she was “actually innocent” and set her free. Lambert v. Blackwell, No. 04-1571 A unanimous three-judge panel of the 3d U.S. Circuit Court of Appeals sharply criticized U.S. District Judge Stewart Dalzell’s handling of the case, finding that in his decision to set aside Lambert’s conviction for the 1991 murder of Lancaster, Pa., teen Laurie Show, he had failed to accord the appropriate level of deference due to findings of Pennsylvania’s state courts. “The writ of habeas corpus . . . empowers a federal court to overturn a state conviction only when it is contrary to federal law or an unreasonable application of law or determination of the facts. Comity and finality . . . mandate considerable deference to the determination of the state fact-finder and appellate courts,” 3d Circuit Judge Michael Chertoff wrote. By contrast, after Dalzell recused himself, the case was handled properly by the new judge, U.S. District Judge Anita B. Brody. “We agree with Judge Brody that Lisa Michelle Lambert . . . was not the victim of a miscarriage of justice,” Chertoff wrote. Lambert had been convicted by then-Lancaster County Common Pleas Judge Lawrence Stengel of the December 1991 murder of Show, a 16-year-old Lancaster high school sophomore. Prosecutors argued that Lambert, now 32, stalked and murdered Show because she thought Show was romantically involved with Lambert’s boyfriend, Lawrence Yunkin. Yunkin and Lambert’s friend, Tabitha F. Buck, were also convicted. Yunkin was released to a halfway house in January. After Lambert filed a habeas petition in federal court, Dalzell appointed attorney Christina Rainville, then of Philadelphia’s Schnader Harrison Segal & Lewis, to represent her. Rainville set out to prove that Lambert was framed by police and prosecutors, who systematically hid valuable evidence from her original defense lawyer. Dalzell agreed, finding that Lambert’s was “the worst case of prosecutorial misconduct in English-speaking experience.” Dalzell set Lambert free and ruled that Lancaster County prosecutors couldn’t try her again. The opinion set off a firestorm as the murder victim’s parents, along with hundreds of Lancaster County residents, called for the judge’s impeachment. Lambert enjoyed only 10 months of freedom because the 3d Circuit reversed Dalzell’s decision on procedural grounds, finding that many of Lambert’s claims had never been presented to the Pennsylvania courts. The intermediate-level Pennsylvania Superior Court upheld the conviction. When Lambert returned to federal court, her case was again assigned to Dalzell, who again declared that Lambert was innocent. Prosecutors then petitioned the 3d Circuit, asking that Dalzell be taken off the case. Dalzell stepped down, and the case was assigned to Brody, who ruled that Lambert “is not, and never will be, innocent of this crime.” On appeal, Lambert’s lawyers urged the 3d Circuit to reinstate Dalzell’s decision. They argued that there had been prosecutorial misconduct: For example, Lambert’s original lawyer was never informed of the existence of an eyewitness whose testimony would have supported her story. The 3d Circuit ruled that Lambert fell short of proving all but two of her claims. And the two minor errors she proved, the court said, were not enough to show that she was not given a fair trial.

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