Klein v. Martin · ¶2
Held: Because the state appellate court's decision—that the undisclosed forensic report was not material under Brady v. Maryland, 373 U. S. 83—neither was “contrary to” nor “involved an unreasonable application” of “clearly established Federal law,” 28 U. S. C. § 2254(d)(1), the Antiterrorism and Effective Death Penalty Act of 1996 required the denial of Martin's federal habeas petition, and the Fourth Circuit erred in affirming the grant of habeas relief. The Fourth Circuit contravened AEDPA's deferential standards in two ways. First, it held that the state appellate court applied the wrong legal rule despite that court's correct citation and summary of Brady materiality precedents. Second, it erred in holding that no fairminded jurist could find that the undisclosed forensic report was immaterial when the record contains strong support for the state court's conclusion that Martin…Read in context ›
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