The following pending petitions involve issues of interest to capital habeas litigators:
Klein v. Martin, 25-51 (cert. petition filed July 11, 2025)
(case below: 2025 WL 215521 (4th Cir.) (unpublished))
Question presented:
The Antiterrorism and Effective Death Penalty Act (AEDPA) establishes a “highly deferential standard for evaluating state-court rulings, which demands that state-court decisions be given the benefit of the doubt.” Woodford v. Visciotti, 537 U.S. 19, 24 (2002) (citation and quotation marks omitted). In this case, a Maryland appellate court rejected respondent’s postconviction claim that the State suppressed evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), holding that there was not a reasonable probability that the result of his trial would have been different had the suppressed evidence been timely disclosed to the defense considering the strength of other evidence establishing his guilt. A divided panel of the Fourth Circuit concluded that although the state court correctly articulated applicable federal law, the state court’s application of that law was unreasonable because its written analysis of the evidence was, in the Forth Circuit’s view, insufficiently “nuanced” and “exhaustive[].” App. 23a, 26a (citation omitted). The question presented is:
Did the Fourth Circuit violate AEDPA’s deferential standard by overturning a state-court decision based on the supposed lack of “nuance” and “exhaustiveness” in the court’s written opinion, rather than the reasonableness of its legal conclusion?