What happened
The U.S. Supreme Court summarily reversed a Fourth Circuit ruling that had upheld habeas relief for Charles Brandon Martin, holding that AEDPA required denial of his Brady-based challenge to a Maryland attempted-murder conviction.
The court granted the state officials' petition, reversed the Fourth Circuit and remanded for further proceedings, while Justice Jackson would have denied certiorari. The per curiam opinion said the Fourth Circuit departed from the constrained role federal habeas courts must play when reviewing state-court merits decisions under the Antiterrorism and Effective Death Penalty Act.
Martin was convicted in Maryland as an accessory before the fact for the attempted murder of Jodi Torok, sentenced to life in prison and had his conviction and sentence affirmed on direct appeal. He later argued that prosecutors violated Brady by failing to disclose a forensic report about computers seized from his home, including a former-employer laptop, that found no use since 2005 and no keyword hits for terms including handgun, Gatorade and silencer.
A state postconviction court ordered a new trial, but Maryland's intermediate appellate court reversed after concluding the report was not material because other evidence linking Martin to the crime was strong. A divided Fourth Circuit affirmed federal habeas relief, but the Supreme Court said the panel erred by treating the state appellate court as having applied the wrong legal rule and by finding that no fairminded jurist could deem the forensic report immaterial.
The Supreme Court said AEDPA bars federal courts from imposing opinion-writing standards on state courts and requires them to give state merits decisions the "benefit of the doubt." The opinion said the state appellate court had correctly stated Brady materiality law, reviewed the entire record and permissibly concluded there was no reasonable probability the trial result would have changed even if the report had severely impeached a prosecution witness.
The justices pointed to evidence they said a fairminded jurist could view as supporting the conviction even without that witness's laptop testimony. That evidence included DNA tied to a modified Gatorade bottle described as resembling a homemade silencer, testimony that Martin was present when a similar bottle and tape were brought upstairs shortly before the shooting, motive evidence, a text to Torok on the day of the shooting, gun evidence and testimony that Martin later told another man to get rid of a brown paper bag.
For habeas practitioners, the ruling reinforces the court's continued insistence that AEDPA review is not ordinary error correction. The next step is further proceedings on remand consistent with the Supreme Court's opinion.