What happened
The U.S. Supreme Court reversed a Fourth Circuit decision that had affirmed habeas relief for Charles Brandon Martin, holding that federal courts owed AEDPA deference to a Maryland appellate court's rejection of his Brady materiality claim.
In a per curiam opinion, the court said the state appellate court's decision that an undisclosed forensic report was not material under Brady v. Maryland was neither contrary to nor an unreasonable application of clearly established federal law. That meant the Antiterrorism and Effective Death Penalty Act required denial of Martin's federal habeas petition, not a new trial.
Martin was convicted in Maryland as an accessory before the fact in the attempted murder of Jodi Torok and was sentenced to life in prison. His postconviction Brady claim centered on a forensic report analyzing computers found at his home, including a laptop from a former employer; the report found no evidence the laptop had been used since 2005 and no keyword hits for terms including handgun, Gatorade, silencer and homemade silencer.
Martin argued the report undercut testimony from Sheri Carter, who said he had used a laptop at her home to research gun silencers before the shooting. The Maryland appellate court held the report was not material, concluding that even if it totally discredited Carter, the other evidence linking Martin to the crime was strong enough that there was no reasonable probability of a different trial result.
The Supreme Court said the Fourth Circuit went wrong twice: first by treating the Maryland court as if it had applied the wrong Brady materiality rule despite citing and stating the correct standard, and second by concluding that no fairminded jurist could view the forensic report as immaterial. AEDPA, the court said, bars federal courts from imposing opinion-writing standards on state courts and requires giving state merits decisions the benefit of the doubt.
On the record, the justices said there was "strong support" for the state court's conclusion that Martin would have been convicted even if the report severely impeached Carter. The opinion pointed to DNA and other evidence tying Martin to a modified Gatorade bottle that resembled a homemade silencer, evidence suggesting he was present when the bottle was modified, motive evidence tied to Torok's pregnancy and child-support threat, and evidence that Martin owned the type of gun that appeared to have been used.
The court granted the state's certiorari petition, reversed the Fourth Circuit and remanded for further proceedings. Justice Jackson would have denied certiorari.