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Supreme Court Summarily Reverses Fourth Circuit in Klein v. Martin, 8–1

The per curiam order says the Fourth Circuit failed to apply AEDPA’s deferential review, returning the case for further proceedings.

Overview

  • The Court held that the Fourth Circuit departed from what AEDPA prescribes when it affirmed federal habeas relief in an unpublished decision.
  • Justice Ketanji Brown Jackson noted a lone dissent by stating she would have denied certiorari without issuing an opinion.
  • Charles Brandon Martin’s Maryland conviction for the attempted murder of Jodi Torok had survived state appellate review after a state postconviction grant of a new trial was reversed.
  • The undisclosed forensic report indicated no keyword hits for terms linked to alleged online searches about silencers, but the Supreme Court said a fair‑minded jurist could conclude disclosure would not have changed the verdict under Brady’s materiality standard.
  • The judgment is reversed and the case is remanded, marking another summary correction of a Fourth Circuit habeas ruling this term following November’s decision in Clark v. Sweeney.