BEFORE THE GOVERNOR FOR THE STATE OF TEXAS
AND
THE BOARD OF PARDONS AND PAROLES
In re
CLARENCE ALLEN LACKEY,
Petitioner
SUPPLEMENTAL INFORMATION MANDATED BY § 143.42 OF
THE RULES OF THE TEXAS BOARD OF
PARDONS AND PAROLES
IN SUPPORT OF
PETITION FOR REPRIEVE
FROM EXECUTION OF DEATH SENTENCE AND
COMMUTATION OF SENTENCE TO IMPRISONMENT FOR LIFE .
The first time I met Clarence Lackey was also my first trip to death row in
Huntsville’. I, not surprisingly, was a little uneasy. What would I say to this man? What
in the world would we have in common? Agonizing over these questions on the drive out
there, I decided I would just keep the conversation on a professional level. We could
discuss his appeals and, if I could help him in any other way, I would be more than
willing.
Passing through the gates, signing in at the front desk, I sat down in the visitor’s
room and waited for this man to come out. After what seemed like an eternity, he was
there and, within minutes, all those anxieties were gone.
Clarence Allen Lackey is in his early forties and when he sits down across from
you in the visitors’ area, he always smiles, thanks you for helping him, and asks how you
are doing. His brown hair, which he fastidiously combs back, is starting to thin on top
and his stomach is beginning to show the impact of twenty years of prison fare. He is of
average height and his appearance is largely unremarkable. Yet when he smiles, which
he does often, his eyes shine with a happiness that hides a tragic past. He follows
baseball, especially the Texas Rangers, and looks forward to watching the Indianapolis
500 every year. My meetings with Clarence are more about sports and news than they are
about appeals and the law.
Sometimes when we are talking, he stops, shakes his head, and looks down at his
hands. A moment or two later, he looks up and with sad eyes he tells me how much he
’The experiences described in this portion of the petition are those of Collie James, a law student at the
| University of Texas School of Law in Austin. Mr. James worked on Mr. Lackey’s case through the Capital Punishment
Clinic.
wishes he would have listened to his parents when he was young. That is Clarence’s
advice and he tells it to everyone who will listen. They might not be perfect and they
may tell you things you do not want to hear, but your parents always know what is best
for you. With eyes that belie a sadness and weariness that he cannot hide once he stops
smiling, Clarence looks at me and I know in his mind that he is a kid again and he is
walking away from the influences that led him to the table across from me.
Clarence Lackey brings this clemency petition before the Governor and the Board
of Pardons and Paroles to allow him to make a few steps in that direction. He seeks a
thirty day stay of execution in order to conduct DNA testing on evidence that can
conclusively establish his role in the crime for which he was convicted. Suffering from
an alcoholic blackout on the night of the murder of Toni Kumph, Clarence Lackey has
spent twenty years on death row agonizing over that missing night. Today, technology
exists to give Clarence the certainty that will provide him with the strength to face his
future.
Mr. Lackey also brings a request with this petition for the commutation of his
sentence to life imprisonment. For fourteen of his twenty years on death row, Clarence
waited for the courts of the State of Texas to finalize his conviction and sentence. May
20, 1997, is his seventh execution date. Four times he has been spared with last minute
stays, two of which came within hours of his death. Twice, the United States Supreme
Court has indicated that such a roller-coaster ride violates the Federal Constitution. The
merits of his claims, however, have never been heard in a court of law due to procedural
technicalities.
With the recent changes in the habeas corpus law, the Governor’s Office must
accept a heightened role in the administration of the death penalty. These new procedural
barriers mean that the Governor will often be the only forum for inmates to bring their
claims. No longer do clemency petitions represent a last ditch effort to push aside the
conclusions of endless courts that have heard, considered, and dismissed innumerable
claims on the merits. Today, the Governor and the Board are the first and only forum
able to hear Clarence Lackey’s story.
A. Clarence Allen Lackey
Clarence Lackey was born in El Paso on August 3, 1954. His mother, Ann
Lackey, almost died during childbirth and when his father was told that the doctors could
only save one of them, his father, Joe, chose to let Clarence die. Clarence, however,
surprised them all and pulled through after an emergency cesarean delivery. It was
Clarence’s first struggle to find a place in his father’s home but it was a struggle that
lasted until he finally left to make a life for himself at age nineteen.
Life in the Lackey home was a difficult and often terrifying battle to make it from
day to day. There was young Clarence, his mom and dad, and when Clarence was six, his
sister Joann was born. The Lackeys moved from trailer park to trailer park and Clarence
never had the opportunity to settle in, make friends, and live the normal life of a young
boy. The family stayed in El Paso for several years before moving on to Arkansas.
Clarence spent some time in Alabama with his grandparents but returned to take care of
his mother and sister. The family finally ended up in Lubbock where Clarence spent his
teenage years.
School was always difficult for Clarence and his mother describes him as a “slow
learner.” Clarence’s earliest memories are from junior high, where he recalls the special
education classes he took because of his “slowness.” IQ tests revealed that intellectually
he is borderline mentally retarded and expert medical tests determined that he suffered
from learning disabilities that further limited his scholastic opportunities. His grade
school transcripts record an “F’” for all subjects except physical education and art. He had
a joy and aptitude for drawing and painting and, in that world, he found one subject in
which he felt he could succeed. That passion continues to today; he enjoys the comic
illustrations of Calvin and Hobbes and, in his letters, one will often find cheerful doodles
that convey the emotions he is unable to express with words. Clarence also excelled in
citizenship, where he received and “A” or “B” every year, and his teachers noted that he
was cheerful, courteous, worked well, and followed directions.
Clarence, feeling that is was time to become a man and support himself, dropped
out of school in tenth grade and began working. It is a decision he regrets to this day
because of the limitations it put on his future and has worked hard during the last twenty
years on death row to improve his reading and writing skills. For him, it is one of the few
small ways he can take back the mistakes he made along the way.
The one constant in Clarence’s life was his father’s explosive violence that
followed his nightly alcoholic binges. Joe Lackey was a trucker most of his life, which
kept him on the toad for long stretches of time. Instead of looking forward to his return,
however, Clarence, Joann and Ann Lackey cringed at the prospect, aware of the insults,
beatings and broken furniture that were sure to follow the empty bottles. The children
avoided being alone with their father out of pure terror and would wait at the park until
their mother got off work so that she could protect them. When the children were young,
Mrs. Lackey would distract the rampaging Joe long enough for Clarence and Joann to slip
out of the trailer to safety. The next day, after Joe had passed out, they would return to
see on their mother the sacrifice she made to protect her children. When Clarence was
fourteen, he stopped letting mother step in the way. Instead, he would distract his father,
letting his mother and sister escape, and let Joe exhaust his rage by taking the beatings
until his father finally grew tired and stopped. Clarence never fought back.
Unable to find refuge in his schoolwork and terrified to go home, Clarence, not
surprisingly, was a shy and solitary young man. He hardly talked, never discussed his
emotions, and found it difficult to make friends. He and Joann would often dream of
what it would be like to live in a happy, normal family. The two attended church
regularly, without their parents, because it was the one place in their lives that offered the
prospect of a happy future.
Clarence longed for a relationship with his father. Despite all the pain and terror,
he desperately wanted to forge a bond with this man. Eventually they found a common
ground in alcohol. Joe Lackey first handed his bottle to Clarence when he was ten years
old. He took the bottle in order to prove to his father that he was a man; to make the man
who once had chosen to let him die know that he was a tough kid of whom his father
could be proud. Soon after, he found himself in trouble with the law, compiling a
juvenile record with numerous petty offenses such as breaking curfew and minor in
possession. The police seemed to be at every turn. The record that trailed behind Joe
Lackey was a long one, including ten years in prison for the attempted murder of a black
man he felt was following his wife, and the police kept an eye on Clarence in case he
turned out like his dad.
After leaving school, Clarence made the turn in his life that has haunted him
since. Against his mother’s warnings, Clarence fell in with the wrong crowd, staying out
all night drinking and carousing. It was the late ‘60’s then and drugs were common and
freely available. Soon Clarence and his friends were breaking into houses in order to
fund their partying and eventually Clarence found himself in jail for burglary. Leaving
prison, Clarence tried to turn his life around, moving in with his girlfriend and finding
steady work as a welder for a tent-building company.
Unfortunately, Clarence could not escape his alcoholism, which continued to
grow steadily worse. In the months preceding his arrest, Clarence would often wake
unable to remember anything about the previous night. It appeared as if the prophecy
was being fulfilled. Clarence was becoming Joe as son followed father into self-
destruction. Clarence, however, is not his father. He was always gentle with his mother
and sister and never exhibited any violence around his girlfriends. Most importantly,
Clarence is acutely aware of the pain that he has caused people in his life and now, in the
rare opportunities that arise on death row, he tries to atone for those mistakes by being a
source of strength and an example to those around him.
B. Trial and Appellate History
In early August of 1977, the State of Texas indicted Clarence Allen Lackey for
the July 31, 1977, capital murder of Toni Kumph in Lubbock. Mr. Lackey was
immediately arrested and has remained in incarceration for the last two decades.
Tried in Tom Green County on a change of venue from Lubbock County,
Clarence Lackey was convicted of capital murder and sentenced to death in the spring of
1978. Mandatory direct appeal to the Texas Court of Criminal Appeals followed his
conviction. For fifty-four months his appeal sat pending until September 15, 1982, when
the court reversed his conviction because of the improper exclusion of a juror based on
her views on the death penalty. Lackey v. State, 638 S.W.2d 439, 471-476 (Tex. Crim.
App. 1982).
The case was then remanded to the trial court for a new trial. A change of venue
to Midland County followed, whereupon Mr. Lackey was tried and again convicted of
capital murder and sentenced to death in April of 1983. Clarence returned to death row
and mandatory appeal to the Court of Criminal Appeals once again followed. This time
the CCA waited eight years before ruling on Mr. Lackey’s claims, finally affirming the
conviction and sentence in late 1991. See Lackey v. State, 819 S.W.2d 211 (Tex. Crim.
App. 1989)(on original submission); id. at 128-141 (Tex. Crim. App. 1991)(on
rehearing). No petition to the United States Supreme Court followed and ninety days
later Clarence’s conviction became final. It took over fourteen years -- from early 1977
to late 1991 -- for the State to secure a final sentence against him. When his first
execution date was set for July 17, 1992, Clarence Lackey had been under sentence of
death for over 5000 days, most of which was spent waiting for the courts to examine his
automatic mandatory appeals.
The trial court stayed his first execution upon the filing of his first state habeas
corpus petition. The State, suddenly interested in Clarence, hurried his appeals along and
the first round of state and federal discretionary appeals were completed in January 1995.
During this time, Mr. Lackey faced two more execution dates -- on October 17, 1992 ,
and December 17, 1992 -- while he was attempting to locate volunteer state habeas
counsel. The trial court again stayed the second execution date. The federal district court
granted Mr. Lackey his third stay on December 16, 1992, mere hours before his
scheduled execution. After the Supreme Court denied review of his federal habeas
petition on January 9, 1995, his first round of discretionary appeals came to a close. The
State immediately responded by setting a fourth execution date for March 5, 1995.
In February of 1995, Clarence filed a second habeas application in the Texas
Courts raising only an Eighth Amendment claim. Mr. Lackey claimed that it was cruel
and unusual punishment to be held under sentence of death for eighteen years, a large
portion of it waiting for the State to rule on his mandatory appeals. The Texas courts
dismissed his claim without ever addressing its merits, at which point Mr. Lackey filed a
petition for a writ of certiorari with the United States Supreme Court. Pending the
outcome of the petition, Clarence’s fourth execution date was stayed by the Supreme
Court on March 3, 1995, two days before the scheduled execution.
The Supreme Court denied the petition on March 27, 1995. Two Justices --
Justices Stevens and Breyer -- explicitly stated that Mr. Lackey’s claim was “important”
and should be carefully examined by the lower courts and that the denial should not be
viewed as a ruling on the merits. Lackey v. Texas, 115 S. Ct. 1421, 1421-1422 (1995).
The next morning, Mr. Lackey filed his second federal habeas petition in district court in
order to give the lower courts the opportunity to examine his Eighth Amendment claim.
One hour later, the State set his fifth execution date for April 28, 1995.
The federal district court soon issued a stay of execution and granted a motion to
hold an evidentiary hearing on the claim the Supreme Court had recognized as
“important.” The State immediately appealed to the Court of Appeals for the Fifth
Circuit which vacated the stay after ruling that Mr. Lackey’s claim was procedurally
barred because it should have been brought earlier. This, of course, was an amazing
tuling considering the substance of the claim. The Fifth Circuit never considered the
merits of the Eighth Amendment claim. On the eve of his fifth execution date, Clarence
Lackey again made an appeal to the United States Supreme Court. At 9:00 p-m. on April
27, 1995, just three hours before poison was to begin flowing into Clarence’s arms, the
Supreme Court reinstated the district court’s stay, effectively reversing the Fifth Circuit’s
order. Exhausted, Clarence was led back to his cell to wait for his sixth date. His only
source of relief was that for the second time the highest court in the land had hinted at the
validity of his Eighth Amendment claim.
An extensive evidentiary hearing was finally held in the district court, where, at
long last, Clarence was able to present substantial evidence of the extreme psychological
toll of spending nearly two decades waiting to be killed. Despite an adverse ruling by the
Fifth Circuit in a related case which was decided in the middle of the evidentiary hearing,
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the district court continued the evidentiary hearing to its conclusion. However, the
district court was bound by the Fifth Circuit’s ruling in the related case, and dismissed
the application because of the procedural barrier. Again, no legal conclusions were made
on the merits. The Fifth Circuit quickly affirmed, again, without ever reaching the
merits. Lackey v. Johnson, 83 F.3d 116 (Sth Cir. 1996). Left with only the legalities of
the procedural bar to examine, the Supreme Court denied certiorari. Lackey v. Johnson,
117 S. Ct. 276 (1996).
In October of the same year, Clarence received his sixth execution date, set for
November 15, 1996. Remarkably, Mr. Lackey received another stay pending the Court
of Criminal Appeals’ disposition of a shared claim raised in another inmate’s appeal. In
March, the Court of Criminal Appeals denied relief in that case, thereby lifting the stay.
A few days later, Clarence was notified of his seventh execution date when his mother
called one of his attorneys after hearing about it on the news. It is now scheduled for
Tuesday, May 20, 1997.
C. Reasons Why Mr. Lackey’s Death Sentence Should be
Commuted to Life Imprisonment
A new era has dawned on the administration of criminal justice in this country. In
no area of the law have those changes had a greater impact than in the implementation of
capital punishment. When the Federal Anti-Terrorism and Effective Death Penalty Act
came into force on April 23, 1996, the protections that were guaranteed to death row
inmates around the country were fundamentally altered. The Act’s changes marked the
11
final step in a series of developments in both state and federal law that created new rules
for those seeking relief by habeas corpus petition. Among those were sharp limits on a
court’s ability to review the decision of the lower courts, speedy time limits on the filing
of appeals, and, most importantly, very strict limitations on the ability to overcome
procedural barriers to allow review of claims on the merits. All of these were recently
held by the Fifth Circuit to apply retroactively to all inmates, including Mr. Lackey.
These developments were the result of the democratic process attempting to find a
balance between the rights of inmates and society’s legitimate interest in finality.
This is not the appropriate forum to dispute the propriety of those changes. Their
existence, however, fundamentally alters the role of the Governor and the Board in the
process. Since the reintroduction of the death penalty in 1976, the Governor’s Office has
always been able to assume -- correctly -- that the courts had thoroughly examined every
last appeal by the time the clemency petitions reached their desks. Accordingly, the
Governor and the Board’s power was reserved for only the most exceptional of cases.
These recent alterations swept away the validity of that assumption and, thus, require a
new diligence in the Governor’s oversight of the process. The limits on multiple petitions
and nearly insurmountable procedural barriers mean that clemency petitions such as this
one will be the only forum for the review on the merits of legitimate and compelling
claims.
Clarence Lackey’s situation today is a perfect example of the need for the closer
involvement of the Governor and the Board in the future. Although most of Clarence
Lackey’s time on death row predated the new Act, his experience personifies these
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concerns. Twice, the United States Supreme Court has extraordinarily expressed the
legitimacy of his claim that prolonged detention on death row due to state-created delay
in resolving mandatory appeals violates the cruel and unusual punishment clause of the
Eighth Amendment of the United States Constitution. Tragically, despite that
endorsement, procedural technicalities have prevented any court from considering the
merits of the claim. One day, another inmate similarly situated will come before the
Court and may prevail. For Clarence Lackey, however, the only forum for his claim is
the Governor’s Office.
The arguments and issues that these courts have been unable to hear are both
compelling and disturbing. Moreover, the cruelty of subjecting an inmate to both a life
sentence and the death penalty has been recognized in courts across the globe.
* "There is an instinctive revulsion against the prospect of
[executing] a man after he has been held under sentence of
death for many years. What gives rise to this instinctive
revulsion? The answer can only be our humanity; we
regard it as an inhuman act to keep a man facing the agony
of execution over a long, extended period of time.'”
"[T]here is a formidable case for suggesting that execution
after inordinate delay would have infringed the prohibition
against cruel and unusual punishment to be found in
Section 10 of the Bill of Rights of 1689...."°
The execution of a prisoner pursuant to a constitutionally-obtained judgment is
not cruel and unusual punishment per se under the Eighth and Fourteenth Amendments to
? Pratt & Morgan v. Attorney General of Jamaica, Privy Council Appeal No. 10 of 1993, slip op., at 16,
reported at 3 WLR 995, 143 NLJ 1639, 2 AC 1, 4 All ER 769 (British Privy Council Nov. 2, 1993) (en banc).
* Riley v. Attorney General of Jamaica, 1 AC 719, 3 All ER 469 (Privy Council 1983) (Lord Scarman,
dissenting, joined by Lord Brightman), majority opinion overruled by Pratt & Morgan v. Attorney General of Jamaica,
2 AC 1, 4 All ER 769 (Privy Council 1993) (en banc).
13
the United States Constitution. However, it has long been recognized that while the death
penalty itself may not be a cruel and unusual punishment, the manner of its imposition
may violate the Eighth Amendment depending on the circumstances. As discussed
above, the Supreme Court of the United States has twice indicated the legitimacy of this
claim. It is now the Governor’s duty to finally consider and accept the merits of that
argument.
Because of the unusual circumstances surrounding the State's attempt to
implement capital punishment in this case, the State of Texas has forfeited its right to
execute Clarence Lackey under the Eighth and Fourteenth Amendments. This forfeiture
has resulted both from the inordinate amount of time that Mr. Lackey has spent on Texas'
death row and the State’s unnecessary setting of repeated execution dates in his case.*
Largely the result of unnecessary delays by the Texas courts in hearing Mr. Lackey's two
mandatory, automatic direct appeals, Mr. Lackey has been required to spend almost two
decades on death row. To execute Mr. Lackey at this late date exceeds the limits that our
Constitution places on the punishment of those who violate society’s laws. Accordingly,
* The first three execution dates scheduled in this case were set by the Texas trial court solely in order to force
Mr. Lackey to initiate his habeas corpus appeals in state and federal court. It is widely understood by members of the
bench and bar in Texas -- although not understood by death row inmates facing such execution dates -- that in the
overwhelming majority of Texas capital cases, such premature execution dates will not result in an actual execution.
Judge Edith Jones of the U.S. Court of Appeals for the Fifth Circuit has noted this largely peculiar Texas practice of
setting premature execution dates solely to force the immediate filing of habeas corpus appeals by death row inmates.
See Hon. Edith Jones, Death Penalty Procedures: A Proposal for Reform, 53 TEX. BAR J. 850, 851 (1990) (referring
to the practice as "[dJocket control by execution date"); see also Mark Ballard, Death Penalty System Ridiculed, TEXAS
LAWYER, May 11, 1992, at 4 (quoting Fifth Circuit Judge Thomas Reavley's criticism of Texas’ system of "jump-
starting" habeas corpus appeals by setting premature execution dates).
Mr. Lackey does not dispute that the state has a legitimate interest in seeing that habeas corpus appeals are pursued
efficiently by death row inmates; however, considerably less cruel methods are available to assure that habeas corpus
appeals are pursued by death row inmates in an efficient manner than Texas' preferred method of setting execution dates.
14
Clarence Lackey should be allowed to serve the life sentence the State of Texas has
chosen to give him.
D. Reasons Why A 30 Day Reprieve Should Be Granted
After nearly twenty years on death row waiting to die, Clarence Lackey will not
tell you that looking death in the face six times has been the hardest part of the last two
decades. For him, spending those years with only a black abyss where the night of July
31, 1977, should be is the greatest pain. To know for certain whether it was his own
hands that took the life of Toni Kumph would give Clarence the comfort and strength he
needs to face God. That alcoholic blackout has robbed Mr. Lackey of the ability to
accept the justice that awaits him. Today, the technology exists to grant Mr. Lackey that
last request. Unfortunately, the trial court in Lubbock refused to order the release of
evidence for DNA testing to be paid for by Mr. Lackey. The Governor and the Board are
Mr. Lackey’s last chance to find comfort at the end. Accordingly, Clarence Lackey
respectfully requests the State of Texas to grant him thirty days to conduct the DNA
testing. If the results miraculously exculpate Mr. Lackey, we can all rest knowing that
justice truly has been served. If, on the other hand, the tests prove conclusively that
Clarence Allen Lackey murdered Toni Kumph, Clarence is willing to face the
consequences of that act if the State wishes to execute his death sentence.
Clarence does not seek to relitigate his case with this request. The time to present
evidence drew to a close many years ago. Rather, Mr. Lackey seeks what two trials and
nineteen years of appeals could never give him. In addition to the simple difficulty of
connecting this crime to the boy who would suffer horrible beatings without reaction to
spare his mother and sister the same pain, inconsistencies in the evidence provide a
reasonable source of doubt in Clarence’s mind. Notable among these:
> A witness testified that he saw a man leaving the victim’s house, get into a
white pick-up truck and drive away. The witness claimed that he saw a woman
slumped over the truck’s seat and that the driver of the car roughly matched Mr.
Lackey’s appearance. Mr. Lackey did drive a white pick-up, but it was a
Chevrolet, not the Ford that the witness claimed he saw. Moreover, the witness
testified that the only notable aspect of the vehicle was a missing hubcap. He
never mentioned the flashy air horns and running lights that ostentatiously
adorned the roof of Clarence’s truck.
> The witness also described the man driving the white pick-up as having
long hair and a mustache. Mr. Lackey, however, had short hair and side burns.
No line up was performed at the time of his arrest, just a few days after the
murder, to allow the witness to positively identify the man he saw that night while
the memory was fresh in his mind.
> No autopsy was ever performed on Ms. Kumph. Examinations of
photographs of the body by a board certified forensic pathologist revealed no
evidence of sexual assault. Rape was the sole aggravating factor that made Mr.
Lackey eligible for the death penalty at trial.
Clarence Lackey does not come to you arguing that these inconsistencies mandate
his immediate release. He only seeks permission to lay his doubts to rest. After twenty
years, most of which were the result of state-created delay, and six execution dates, it is
the least the State of Texas can do for Clarence Lackey. The testing is to be paid for by
Mr. Lackey and the only assistance he seeks from the State is the permission to obtain the
evidence for the test. It is said that the death penalty serves two purposes; as a deterrent
to crime and as retribution for the most heinous of crimes. Neither of those goals are
advanced when the man put to death genuinely has no recollection of the night at issue.
Clarence Allen Lackey only seeks the truth. Please grant him that last request.
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E. Conclusion
The execution of Clarence Allen Lackey will serve none of the purposes for which
the State of Texas imposes the death penalty on those convicted of capital murder.
Twenty years waiting for death and six previous occasions where that day became
concrete only to be spared at the last minute is a far greater punishment than death itself.
That pain becomes even more agonizing knowing that alcoholism robbed Mr. Lackey of
any memory of the night which landed him on death row. Having suffered greatly
already under those circumstances, the State’s interest in retribution is more than satisfied
with life imprisonment. Moreover, death as a deterrent to future crime is undermined
when death is only a distant, uncertain threat. Without either of these justifications, the
execution of Clarence Lackey next Tuesday will just be the purposeless extinction of
another human life.
Clarence Lackey has been punished with a life sentence and a death sentence and
the courts are unable to address the injustice in this double sentence. Accordingly, the
Governor, upon the recommendation of the Board of Pardons and Paroles, should
officially commute Clarence Lackey’s sentence to the life sentence that he has already
been serving. Over the last twenty years, Clarence has proven himself the type of inmate
that will be a benefit in the general prison population. He has defeated the alcoholism
that sent him to prison in the first place. He has struggled to overcome the intellectual
limitations that have plagued him since his difficult birth. He has proven his hard-
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working, industrious nature by spending most of his time on death row as a work-eligible
inmate. In sum, he has escaped the ghost of his father and hopes to have the opportunity
to impart the lessons that he has learned and spread the advice that he gives to me every
time we meet.
Thirty years ago, Clarence stepped in front of his father’s violent rampage to save
his mother and sister from certain suffering. With the grace of the Governor and the
Board, Clarence Allen Lackey may yet again be able to prevent another innocent person’s
pain by being a positive influence to those inmates who may once again re-enter society
after serving their sentences.
Rita J. Radostitz Collie F. James IV
Attorney at Law 3304 Red River, #206
P.O. Box 296 Austin, TX 78705
Austin, TX 78767
512-320-8300
Attorney for Clarence Allen Lackey
REQUIRED EXHIBITS
LETTER FROM CLARENCE LACKEY
TO THE BOARD OF PARDONS AND PAROLE
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