The U.S. Supreme Court on Monday ditched a Fourth Circuit ruling that affirmed habeas corpus relief for a Maryland man convicted of attempted murder, saying the appeals court overstepped federal habeas limits by second-guessing a state court's decision.
In a per curiam order simultaneously granting Maryland's petition for review and issuing a decision, the justices said the Fourth Circuit incorrectly applied provisions of the Antiterrorism and Effective Death Penalty Act of 1996, or AEDPA, that impose strict limits on when a federal court can set aside a state court's verdict.
In the order, the justices criticized the Fourth Circuit for concluding that a Maryland appellate court disregarded certain evidence and failed to evaluate other evidence in a sufficiently "nuanced" manner when it declined to order a new trial for Charles Brandon Martin, who was convicted of attempting to murder his girlfriend, Jodi Torok, in 2008.
"That holding was a basic misapplication of AEDPA, which bars federal courts from imposing opinion-writing standards on state courts and demands that the relevant state-court decision be given the 'benefit of the doubt'," the order says.
The only opposition came from Justice Ketanji Brown Jackson, who would have denied review and let the Fourth Circuit ruling stand.
Torok was found lying unconscious in her home with a gunshot wound to the head on Oct. 27, 2008. Martin had been dating Torok for about a year when she told him she was pregnant and believed he was the father. Martin, who was married to another woman, demanded she get an abortion, but Torok refused, saying she would seek child support in court and threatening to tell Martin's partner about the pregnancy.
On the day of the shooting, Martin texted Torok asking what time she worked. She replied that she was off that day, indicating she would be home. Later that day, Torok was on the phone with a friend, Blair Wolfe, when a man claiming to be a salesman knocked on her door. She ended the call to answer the door and never called back.
Wolfe repeatedly tried to reach her, then contacted Torok's roommate, Jessica Higgs. Higgs returned home and found Torok wounded. The front door was unlocked and there were no signs of forced entry.
Although a weapon was never recovered, investigators found a .380-caliber bullet and shell casing, as well as a Gatorade bottle modified with medical tape and duct tape, with a hole in the bottom and residue consistent with having been used as a homemade silencer. DNA testing tied Martin to the bottle through hair and saliva samples, and witnesses testified he frequently drank Gatorade.
A Maryland jury convicted Martin as an accessory before the fact, and the trial court sentenced him to life in prison. His conviction and sentence were affirmed on appeal.
Martin challenged his conviction in state habeas proceedings, arguing that state prosecutors had infringed his right to a fair trial by failing to disclose a forensic report that appeared to discredit the claim by another girlfriend of Martin's, Sheri Carter, who testified that he had used one of his laptops to look up gun silencers on the internet not long before the shooting.
The postconviction court granted a new trial in light of that evidence, but a unanimous panel of the Maryland Court of Special Appeals reversed on the ground that the report, even if disclosed, wouldn't have changed the outcome of Martin's criminal trial because the other evidence in the case was "strong."
A federal district court granted Martin habeas relief in light of the undisclosed forensic report. A divided panel of the Fourth Circuit later affirmed, holding that although the state appellate court correctly stated the rules set forth by the U.S. Supreme Court for granting habeas relief, it failed to apply the correct analysis.
On Monday, the Supreme Court said the federal court should have denied Martin's habeas corpus petition. The justices took issue with the Fourth Circuit, saying it disregarded high court precedent directing lower courts to grant habeas relief only to remedy "extreme malfunctions" in state court rulings dealing with constitutional claims.
The text of Section 2254(d)(1) of Title 28 of the U.S. Code, one of the AEDPA's core provisions, expressly denies habeas relief to a person whose constitutional claims have been adjudicated in state court unless the adjudication "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States."
"As we have noted many times, AEDPA sharply limits federal review of habeas claims raised by state prisoners," the per curiam order said. "AEDPA requires deference even if the state court does not discuss the evidence at all."
In the order, the Supreme Court also said the Fourth Circuit "went astray" in holding that the undisclosed forensic report about Martin's laptop was material — meaning it could have affected the outcome of his trial.
The justices said the DNA evidence linking Martin to the Gatorade bottle, the additional testimony indicating that he was present when the bottle was modified, as well as circumstantial evidence all pointed to Martin's guilt.
"Based on all the evidence, a fairminded jurist could easily conclude that disclosure of the forensic report on the laptop would not have made a difference," the high court said in the order.
Martin is currently being held in home detention under the supervision of the Department of Detention Facilities for Anne Arundel County, Maryland.
Attorneys for both parties did not immediately respond to comment requests on Monday.
Christopher Klein, the superintendent of the Department of Detention Facilities for Anne Arundel County, is represented by Andrew John DiMiceli of the Maryland Office of the Attorney General.
Martin is represented by Parker Andrew Rider-Longmaid of Skadden Arps Slate Meagher & Flom LLP.
The case is Klein v. Martin, case number 25-51, in the Supreme Court of the United States.
--Editing by Alex Hubbard.
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Justices Nix 4th Circ. Ruling That Affirmed New Criminal Trial
By Marco Poggio | January 26, 2026, 3:06 PM EST · Listen to article