Wetzel v. Lambert

The Third Circuit failed to assess the state court’s determinations for reasonableness under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).

A Pennsylvania court convicted and sentenced Respondent to death for murder during a robbery. Respondent filed a claim for post conviction relief in state court. He alleged that the Commonwealth had committed a Brady violation at trial because it failed to disclose a “police activity sheet” that included information that could have been used to impeach the Commonwealth’s main witness. The Pennsylvania Supreme Court held that the contents of the document would not have materially furthered the impeachment of the Commonwealth’s witness at trial and that the information in the document was “entirely ambiguous.” Respondent filed a petition for a writ of habeas corpus in district court. The district court denied the writ holding that the state courts’ decision was “reasonable.” On appeal, the Third Circuit Court of Appeals reversed and granted the writ concluding that it was “patently unreasonable” for the Pennsylvania Supreme Court to hold that when a witness is impeached in one manner, any other impeachment evidence would be immaterial.

The Supreme Court granted certiorari and vacated the Third Circuit’s judgment. The court explained that, under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a federal court may not grant a writ of habeas corpus to a state prisoner unless each ground supporting the state’s decision is found to be an “unreasonable application of, clearly established Federal law.” The Third Circuit did not follow the AEDPA when it assessed the value of cumulative impeachment evidence instead of assessing the reasonableness of the state courts’ conclusion about the content of the document.