This morning, the Supreme Court summarily reversed a decision of the U.S. Court of Appeals for the Fourth Circuit in Klein v. Martin, concluding the Fourth Circuit failed to comply with the Anti-Terrorism and Effective Death Penalty Act (AEDPA) when (in an unpublished opinion), it awarded a new trial for Charles Brandon Martin. The decision was 8-1, as Justice Jackson dissented without issuing an opinion.
The Court's per curiam opinion in Klein explains the basis for the reversal:
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 disagreeable 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. But federal courts are dutybound to comply with AEDPA, and we have granted summary relief when the lower courts have departed from the role AEDPA assigns. See, e.g., Clark v. Sweeney, 607 U. S. ___ (2025) (per curiam); Dunn v. Reeves, 594 U. S. 731 (2021) (per curiam); Mays v. Hines, 592 U. S. 385 (2021) (per curiam); Virginia v. LeBlanc, 582 U. S. 91 (2017) (per curiam); White v. Wheeler, 577 U. S. 73 (2015) (per curiam).
This is such a 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. App. to Pet. for Cert. 115a (App.); see Kyles v. Whitley, 514 U. S. 419, 434 (1995) (the "touchstone of materiality is a 'reasonable probability' of a different result"). 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. 28 U. S. C. §2254(d)(1). 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.
