2025 Term Decisions of Interest to Capital Habeas Practitioners
Klein v. Martin, 607 U.S. ___ (Jan. 26, 2026) (per curiam). In attempted murder case where respondent Martin was convicted as an accessory before the fact in the shooting of his pregnant girlfriend, reversing the affirmance of a grant of habeas relief on a Brady claim because the reasoning by the Fourth Circuit Court of Appeals “departed from what AEDPA prescribed.” A state post-conviction court had granted a new trial but the intermediate state appellate court reversed after finding that the suppressed impeachment evidence was not material. “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 suppressed evidence was a forensic report concerning the contents of a laptop confiscated by authorities from Martin’s home that Martin argued undermined a government witness’s testimony about seeing Martin “looking up gun silencers” on a laptop computer he had removed from the witness’s home after the shooting. (A Gatorade bottle with tape on it and a hole in its bottom was found at the crime scene and the prosecution’s theory was that the bottle was used as a silencer. DNA evidence linked Martin to the bottle and testimony from other witnesses provided circumstantial evidence of his role in converting the bottle to a silencer.) The Fourth Circuit Court of Appeals erred in two ways. First, the appeals court mistakenly accused the state appellate court of applying a sufficiency-of-the-evidence test instead of the materiality rule mandated by Brady, i.e., whether the undisclosed evidence put the whole case in such a different light as to undermine confidence in the verdict. A review of the state appellate court decision shows its adherence to the correct rule. The Fourth Circuit’s claim that the state appellate court applied the wrong rule “because that court failed to discuss certain evidence that tended to undermine the State’s case and because its analysis was not sufficiently ‘nuanced,’” constitutes a “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 second error by the Fourth Circuit was in its conclusion that every fairminded jurist would find that the undisclosed forensic report about Martin’s laptop was material. “On the contrary, the record contains ‘strong support’ for the state court’s conclusion that Martin ‘would have been convicted’ even if the forensic report ‘severely impeached’ [the government witness].”
Ellingburg v. United States, 607 U.S. ___ (Jan. 20, 2026). Restitution under the Mandatory Victims Restitution Act of 1996, which requires defendants convicted of certain federal crimes to pay monetary restitution to victims, is plainly criminal punishment for purposes of the Ex Post Facto Clause.
Barrett v. United States, 607 U.S. ___ (Jan. 14, 2026). Congress did not clearly authorize convictions under both 18 U.S.C. §§924(c)(1)(A)(i) and (j) for a single act that violates both provisions. One act that violates both provisions therefore may spawn only one conviction. (Subsection 924(c)(1)(A)(i) criminalizes using, carrying, or possessing a firearm in connection with a federal crime of violence or drug trafficking crime. Subsection 924(c)(1)(A)(j) prescribes different penalties—including, in certain circumstances, capital punishment—when “a violation of subsection (c)” causes death.)
Bowe v. United States, 607 U.S. ___ (Jan. 9, 2026). 28 U.S.C. section 2244(b)(3)(E), which provides that the denial of authorization “to file a second or successive application” shall not be the subject of a certiorari petition, does not apply to federal prisoners. Also inapplicable to federal prisoners is §2244(b)(1)’s old-claim bar ("[a] claim presented in a second or successive habeas corpus application under section 2254 that was presented in a prior application shall be dismissed.")
Clark v. Sweeney, 607 U.S. ___ (Nov. 24, 2025) (per curiam). Reversing grant of habeas relief where the Fourth Circuit Court of Appeals "transgressed the party-presentation principle by granting relief on a claim that Sweeney never asserted and that the State never had the chance to address." The only claim raised in Sweeney's federal habeas petition was that his counsel was ineffective for failing to investigate whether other jurors had been prejudiced by the impermissible visit to the crime-scene by a juror who was discharged prior to deliberations. Instead of ruling on that claim, "the Fourth Circuit devised a new one," based on a combination of failures from juror to judge to attorney. This “radical transformation” of the ineffective-assistance claim “departed so drastically from the principle of party presentation as to constitute an abuse of discretion.” (Citation omitted.) The judgment is reversed and the case remanded for consideration of the actual claim raised by Sweeney.
Pitts v. Mississippi, 607 U.S. ___ (Nov. 24, 2025) (per curiam). Although in child abuse cases a court may sometimes screen a child witness from the defendant without violating the Confrontation Clause, it may do so only after hearing evidence and making a “case-specific” finding of “[t]he requisite . . . necessity.” Maryland v. Craig, 497 U. S. 836, 855 (1990) "Simply pointing to a state statute that authorizes screening, even one premised on 'generalized finding[s]' of necessity, will not suffice. Coy [v. Iowa, 487 U. S. 1012, 1021 (1988)]." Because the Mississippi Supreme Court departed from these principles, the judgment is reversed. On remand, the State is free to argue, and the Mississippi Supreme Court may consider, whether the constitutional error was harmless under Chapman v. California, 386 U.S. 18 (1967).