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Texas Prison Guards Who Murdered a Convict Sent to Federal Prison

On March 13, 2002, two former Texas prison guards admitted in plea
agreements that they beat a prisoner to death. Their pleas were accepted by
U.S. District Judge Howell Cobb who sentenced them to federal prison.
Joel Lambright Jr. is the son of a former police chief in the small Texas
town of Corrigan. The junior Lambright began his undistinguished
correctional career in February 1994 when, at age 20, he was hired as a
prison guard and assigned to the 2,800-man Charles Terrell (since renamed
Allan Polunsky) State Prison near Livingston, Texas. In 1994, Michael
McCoy, 30, was serving a 6-year sentence at Terrell for burglary and car theft.

On the afternoon of October 7, 1994, during a scuffle on Terrell's exercise
yard, McCoy was among a group of prisoners who reportedly became
belligerent. Weighing only 127 pounds and ravaged by cancer, the frail
McCoy allegedly spat on Lambright during the scuffle.

That same evening, Lambright, prison guard Alex Torres, then 26, and a
third guard went to McCoy's cell. Following a brief quarrel, they opened
the cell door and entered, then kicked, beat, and stomped McCoy as he
begged, "Please stop before you kill me. In answer to his plea, Lambright
kicked McCoy's mouth shut and continued to stomp on his head.

McCoy died of his injuries. "It was an apparent reprisal from the fight
that afternoon," said Carol Vance, then Chairman of the Texas Board of
Criminal Justice. "Three officers entered this person's cell and two
[Lambright and Torres] have now been charged with murder."

On October 11, 1994, Lambright and Torres were arraigned in Polk County
[Texas] court. Each was freed on $50,000 bond. The third guard who entered
McCoy's cell was a trainee who testified for the prosecution.

Lambright's week-long murder trial began in March 1995. During trial
recesses, Dorothy Sue Lambright read bible stories to her son from her
35-pound family bible. On March 16, jurors deliberated about 6 1/2 hours
before finding Lambright guilty of manslaughter, a lesser included offense
of murder. He was the first Texas prison guard in history to be convicted
of killing a prisoner.

On March 17, while the ailing senior Lambright hobbled woefully around the
courtroom on crutches, jurors deliberated another 2 hours before sentencing
Lambright to 10 years in state Prison. In a separate trial, Torres was also
found guilty and sentenced to state prison.

But things are not always as they appear in the Texas criminal justice
system. Corrigan is deep in Texas' redneck territory and ex-police chief
Lambright holds high office in the Good ol Boy fraternity. Amid
backslapping and called-in favors, Lambright's 10-year prison sentence was
quietly reduced to a 3-month stint on shock probation. Torres was granted a
similar reprieve. The case appeared to be closed.

But once again, Texas justice is not-always as it appears. The United
States Attorney in Beaumont, Texas, took an interest and after a long and
tedious investigation, brought federal charges against Lambright and Torres
in 2000. 136th men were charged under 18 U.S.C, §242 for conspiring, to
injure and oppress McCoy.

After weighing the iron-clad case against him, Lambright entered a guilty
plea and, accepted a 97 month federal prison sentence to be followed by 2
Teats of supervised release. He surrendered voluntarily and began his
Prison term on. January 6, 2003. He is now confined at-the Federal
Correctional, Institution in Marianna, Florida, with a projected release
date sometime in 2010.

Torres negotiated a lesser sentence. He is now serving time in federal
prison with a projected release date in 2007.

There is still more to the story. With unshakeable belief in Texas' Good
01' Boy system, Lambright had the unmitigated audacity to appeal his
97-month sentence. He argued that the district court erred in enhancing his
sentence by two levels after finding that. McCoy was a "vulnerable victim."
Because McCoy was completely dependent on the care of prison guards, and
because McCoy was locked in his cell prior to the assault, and because
McCoy could not protect himself from the assaultive guards, the U.S. Court
of Appeals for the Fifth Circuit agreed with the district court's
conclusion that Lambright knew or should have known that McCoy was a
vulnerable victim. The appellate court further agreed that it was not clear
error for the district court to enhance Lambright's sentence.

In a final show of redneck arrogance, Lambright asked the Fifth Circuit to
overrule the district court's refusal to grant a downward departure on his
sentence because his was an "extraordinary case." The Fifth Circuit ruled
it did not have jurisdiction to review Lambright's claim that the district
court erred in declining to depart downward from the sentencing guidelines
and therefore let the 97-month sentence stand. See: U.S. vs. Lambright,
9:00-CR-14 (ED TX 2000), and U.S. vs. Lambright, 320 F.3d 517 (5th Cir. 2003).

Sources: The Beaumont [Texas] Enterprise; The Houston Chronicle, Personal
interviews and correspondence, Prison News Service.

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Related legal case

United States v. Lambright

United States v. Lambright, 320 F.3d 517 (5th Cir. 01/30/2003)

[1] U.S. Court of Appeals, Fifth Circuit


[2] No. 02-40993


[3] 320 F.3d 517, 2003


[4] January 30, 2003


[5] UNITED STATES OF AMERICA, PLAINTIFF-APPELLEE,
v.
JOEL R. LAMBRIGHT, JR., DEFENDANT-APPELLANT.


[6] Appeal from the United States District Court for the Eastern District of Texas


[7] Before Higginbotham, Smith, and Clement, Circuit Judges.


[8] The opinion of the court was delivered by: Per Curiam


[9] Summary Calendar


[10] Joel R. Lambright, Jr. (Lambright), appeals the sentence imposed by the district court following his guilty-plea conviction for willful deprivation, under color of law, of another's constitutional rights under 18 U.S.C. § 242. Lambright, who was working as a corrections officer at a Texas state prison at the time of the offense, assaulted an inmate named Michael McCoy (McCoy), causing his death. Lambright argues that the district court erred in enhancing his sentence by two levels based upon a finding that his victim was a "vulnerable victim" under U.S.S.G. § 3A1.1(b)(1). Lambright also argues that the district court erred in denying his motion for downward departure from the sentencing guidelines.


[11] The sentencing guidelines provide for a two-level increase in the base offense level "[i]f the defendant knew or should have known that a victim of the offense was a vulnerable victim." § 3A1.1(b)(1). For the enhancement under § 3A1.1(b)(1) to apply, the victim must be "unusually vulnerable due to age, physical or mental condition, or . . . otherwise particularly susceptible to the criminal conduct." § 3A1.1(b) & comment. (n.2); see also United States v. Moree, 897 F.2d 1329, 1335-36 (5th Cir. 1990). "We review the district court's interpretation of the guidelines de novo; we review a finding of unusual vulnerability for clear error and to determine whether the district court's conclusion was plausible in light of the record as a whole." United States v. Robinson, 119 F.3d 1205, 1218 (5th Cir. 1997)(internal quotation marks and citations omitted).


[12] The district court based its conclusion that the victim McCoy was a vulnerable victim on the findings that he was completely dependent upon the care of the correction officers, that he was locked in his cell prior to the assault, and that he could not protect himself from the assault. The district court's findings are consistent with our holding in United States v. Clayton, 172 F.3d 347, 353 (5th Cir. 1999), in which we determined that the sentence enhancement under U.S.S.G. § 3A1.3, which applies if the victim was physically restrained in the course of the offense, applied to a former deputy sheriff, who assaulted an arrestee while she lay face down and handcuffed. We noted that the victim "could not defend herself against an assault, and could not flee from harm" and that "[the defendant] took advantage of this restraint and the particular vulnerability of the victim." Id.; see also United States v. Tapia, 59 F.3d 1137, 1143 (11th Cir. 1995) (incarcerated government informant attacked by fellow inmates was vulnerable victim under § 3A1.1; court found that informant "was particularly vulnerable by virtue of his incarceration with [the defendants] and his inability to escape"); United States v. Hershkowitz, 968 F.2d 1503, 1505-06 (2d Cir. 1992) (§ 3A1.1 enhancement applied to prisoner attacked by detention facility guard).


[13] Consequently, we find that the district court's conclusion that Lambright knew or should have known that McCoy was a vulnerable victim was "plausible in light of the record as a whole" and it was not clear error for the district court to enhance Lambright's sentence under § 3A1.1(b)(1). Robinson, 119 F.3d at 1218 (internal quotation marks and citations omitted). "We have jurisdiction to review the district court's decision not to depart downward from the guideline range only if the court based its decision upon an erroneous belief that it lacked the authority to depart." United States v. Yanez-Huerta, 207 F.3d 746, 748 (5th Cir. 2000). "[T]here must be something in the record [to] indicate that the district court held such an erroneous belief." Id. (internal quotation marks and citation omitted).


[14] The record does not reveal that the district court mistakenly believed that it could not depart downward on Lambright's sentence. The record reflects that the district court denied Lambright's requested downward departure after hearing extensive argument from his counsel and considering not only whether there were specific guideline provisions that would support the defendant's request, but also whether this was an extraordinary case that would fit under the general provisions of § 5K2.0. The district court also considered that the defendant's conduct resulted in the victim's death.


[15] Therefore, we do not have jurisdiction to review Lambright's claim that the district court erred in declining to depart downward from the sentencing guidelines in imposing his sentence. Yanez-Huerta, 207 F.3d at 748.


[16] Accordingly, Lambright's sentence is hereby AFFIRMED.