Klein v. Martin
Lower Court: Unknown • Last updated: January 26, 2026
Plain-Language Summary
In a per curiam opinion, the Supreme Court reversed the Fourth Circuit in Klein v. Martin, a habeas corpus case. Charles Brandon Martin was convicted in Maryland state court for the attempted murder of his girlfriend, Jodi Torok. He sought federal habeas relief, which the Fourth Circuit granted despite the strict standards of the Antiterrorism and Effective Death Penalty Act (AEDPA).
The Supreme Court held that the Fourth Circuit failed to properly apply AEDPA's deferential standard of review, which requires federal courts to respect state court decisions unless they are clearly unreasonable. The Court emphasized that federal courts must follow AEDPA even when they might have reached a different conclusion themselves.
Vote Breakdown
Per Curiam(author)
Why This Matters
This decision reinforces the high bar that AEDPA sets for federal courts reviewing state criminal convictions. It continues the Court's pattern of summarily reversing lower courts that grant habeas relief without sufficient deference to state courts, maintaining the balance between federal oversight and state criminal justice systems.