Klein v. Martin · ¶24

Martin sought habeas relief in federal court, and the District Court granted his petition based on the State's failure to disclose the forensic report. A sharply divided panel of the Fourth Circuit affirmed. The majority acknowledged that the state appellate court had correctly stated the rule on materiality set out in our decisions and had claimed to apply that rule. Yet the majority concluded that the state court had not actually done what it said it did—had not held that there was no “reasonable probability” that the disclosure of the forensic report would have changed the verdict— but instead had applied the suffciency-of-the-evidence rule that we condemned in Kyles. App. 21a–22a; see 514 U. S., at 434–435 (a Brady claimant need not show that, “after discounting the inculpatory evidence in light of the undisclosed evidence, there would not have been enough left to convict”).…

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