LAWLOR v. ZOOK

No. 17-6.

909 F.3d 614 (2018)

Mark Eric LAWLOR, Petitioner-Appellant, v. David W. ZOOK, Warden, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: November 27, 2018.


Attorney(s) appearing for the Case

ARGUED: Timothy Patrick Kane , FEDERAL COMMUNITY DEFENDER OFFICE FOR EASTERN DISTRICT OF PENNSYLVANIA, Philadelphia, Pennsylvania, for Appellant. Matthew P. Dullaghan , OFFICE OF THE ATTORNEY GENERAL OF VIRGINIA, Richmond, Virginia, for Appellee. ON BRIEF: Aren Adjoian , FEDERAL COMMUNITY DEFENDER OFFICE FOR EASTERN DISTRICT OF PENNSYLVANIA, Philadelphia, Pennsylvania; Emily Munn , BISCHOFF MARTINGALE, P.C., Norfolk, Virginia, for Appellant. Mark R. Herring , Attorney General, OFFICE OF THE ATTORNEY GENERAL OF VIRGINIA, Richmond, Virginia, for Appellee.

Reversed and remanded by published opinion. Judge Thacker wrote the opinion, in which Judge Motz and Judge Duncan joined.


A Virginia state court sentenced Mark Eric Lawlor to death after his conviction for the capital murder of Genevieve Orange. In recommending the death sentence, the sentencing jury found that there was a probability Lawlor "would commit criminal acts of violence that would constitute a continuing serious threat to society...

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