Donald Eugene Lambert v. James Blodgett, Donald Eugene Lambert v. James Blodgett

This case requires us to interpret and apply the standard of review mandated by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Pub.L. No. 104-132, 110 Stat. 1214 (1996), and to determine the meaning of the phrase “adjudicated on the merits,” which acts as a prerequisite to AEDPA review.

In Washington state court, on December 10, 1997, fifteen-year-old Donald Eugene Lambert pled guilty to aggravated first-degree murder, an offense which carries a mandatory sentence of life in prison without the possibility of parole. Shortly thereafter, Lambert filed a Personal Restraint Petition in the Washington Court of Appeals attacking his plea on the grounds that he was provided ineffective assistance of counsel and the plea was not knowingly, voluntarily and intelligently entered. After unsuccessfully arguing his claims both in the Court of Appeals and the Washington Supreme Court, Lambert petitioned the United States District Court for the Western District of Washington for a writ of habeas corpus.

In his habeas petition, Lambert reasserted his claim of ineffective assistance supported by three primary allegations: (1) his attorney, Guillermo Romero, stipulated to the…