SCOTUS Rules 4th Circuit Erred in Granting New Trial in Klein v. Martin

In Klein v. Martin, 607 U.S. ____ (2026), the U.S. Supreme Court reaffirmed that federal courts must adhere to strict Antiterrorism and Effective Death Penalty Act (AEDPA) standards regarding state court decisions. 

Because the Fourth Circuit Court of Appeals affirmed the award of a new trial based on reasoning that departed from those standards, the Court summarily granted the state’s petition for a writ of certiorari and reversed.

Facts of the Case

Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), strict standards govern the grant of federal habeas relief to prisoners convicted in state court. Faithful application of those standards sometimes puts federal district courts and courts of appeals in the position of having to deny relief in cases they would have analyzed differently if they had been in the shoes of the relevant state court. Nonetheless, federal courts are dutybound to comply with AEDPA.

In this case, Respondent Charles Brandon Martin was convicted in a Maryland court for the attempted murder of one of his girlfriends, Jodi Torok. The evidence against him was strong, his conviction was affirmed on appeal, and an appellate court held in a state postconviction proceeding that the State’s failure to disclose certain impeachment evidence that was favorable under Brady v. Maryland, 373 U.S. 83 (1963), did not warrant a new trial because there was no “reasonable probability that the result of [the] trial would have been different” had the evidence been turned over. 

Martin subsequently sought habeas relief in federal court, and the District Court granted his petition based on the State’s failure to disclose the forensic report. A sharply divided panel of the Fourth Circuit affirmed.According to the Fourth Circuit,the state court had not “exhaustively examined the suppressed evidence” and had failed to provide a “nuanced analysis of the impact of the suppressed evidence on both sides of the case.”

Supreme Court’s Decision

The Supreme Court reversed in a per curium opinion. “Because that decision neither was ‘contrary to’ nor ‘involved an unreasonable application’ of ‘clearly established Federal law,’ AEDPA required the denial of Martin’s federal habeas petition,” the Court wrote. “Yet the Court of Appeals for the Fourth Circuit affirmed the award of a new trial based on reasoning that departed from what AEDPA prescribes. We therefore grant the State’s petition for a writ of certiorari and reverse.”

In reaching its decision, the Supreme court emphasized that the AEDPA “sharply limits federal review of habeas claims raised by state prisoners.” It further explained that the appropriate standard is “whether a decision is contrary to, or involves an unreasonable application of, this Court’s holdings, not whether the state court’s opinion satisfies the federal court’s opinion-writing standards.”

The Supreme Court went on to find that the Fourth Circuit erred in two ways. “First, it grounded its holding that the state appellate court applied the wrong legal rule on its conclusion that the state court had not actually applied the materiality test that it clearly invoked,” according to the Court. Second “it erred in holding that no fair-minded jurist could find the forensic report on the computer to be immaterial,” when, given the evidence against Martin, such a jurist “could easily conclude that disclosure of the forensic report on the laptop would not have made a difference.”