WASHINGTON (CN) - A Maryland man will not receive a new trial for the attempted murder of his pregnant girlfriend, the Supreme Court ruled on Monday, rejecting a lower court ruling overturning his conviction after evidence from his jilted lover was discredited.
In an apparent 8-1 ruling, the justices held that the Fourth Circuit departed from the strict standards governing federal court authority to review state court convictions under the Antiterrorism and Effective Death Penalty Act.
"Faithful application of those standards sometimes puts federal district courts and courts of appeals in the disagreeable position of having to deny relief in cases they would have analyzed differently if they had been in the shoes of the relevant state court," the Supreme Court wrote in an unsigned opinion. "But federal courts are dutybound to comply with AEDPA, and we have granted summary relief when the lower courts have departed from the role AEDPA assigns."
Maryland's petition to block the retrial of Charles Brandon Martin was such a case, the court said.
Martin was convicted for the attempted murder of Jodi Torok, one of his girlfriends. Torok had recently told Martin she was pregnant in 2008 after they'd been dating for a year. Martin was married with two children and was also dating two other women - Sheri Carter and Maggie McFadden.
Prosecutors claim that Torok refused to have an abortion and threatened to take Martin to court for child support. A few weeks after the dispute, Torok was shot in the head at her apartment in Crofton, Maryland.
Torok survived the attack, but her pregnancy did not.
Investigators found shell casings, bullets and a Gatorade bottle that prosecutors say was used as a makeshift silencer. At his trial, Carter testified that she witnessed Martin looking up gun silencers on his laptop not long before the shooting. Carter claimed that he tossed the laptop after the shooting in case their apartment got searched.
The trial judge instructed the jury that Martin could be found guilty if he had aided or encouraged the attempted murder with the intent that the crime succeed. The jury found Martin guilty as an accessory before the fact, and he was sentenced to life in prison.
Years later, Martin discovered that his laptop had not been discarded. Instead, it had been in police custody and a forensic reporter discredited Carter's testimony, finding that Martin hadn't researched silencers.
Martin's attorneys said that prosecutors' failure to disclose favorable evidence to the defense was a clear violation of his Brady rights.
"Had the report been disclosed, it would have destroyed the prosecution's made-for-TV-movie theory," Martin's attorneys wrote. "The report would have discredited Carter's testimony and thus eliminated the only evidence connecting Mr. Martin to silencers."
Prosecutors resisted a new trial, arguing that the report was immaterial.
Two lower courts sided with Martin, granting him a new trial based on the state's failure to disclose the forensic report. The Supreme Court disagreed.
AEDPA is an important but limited safeguard, the justices wrote, that protects against extreme malfunctions in state courts. To receive such relief, the court said prisoners needed to demonstrate that a state court blundered so badly that every fair-minded jurist would disagree with the decision.
"AEDPA requires deference even if the state court does not discuss the evidence at all," the high court wrote. "What matters under 2254(d)(1) - the standard relevant here - is whether a decision is contrary to, or involves an unreasonable application of, this court's holdings, not whether the state court's opinion satisfies the federal court's opinion writing standards."
The justices said that the state court upheld Martin's conviction despite the laptop omission based on prosecutors' other evidence linking him to the crime.
"Based on its review of the 'entire record,' the court found that the evidence 'linking' Martin to the crime was so 'strong' that there was no 'reasonable probability that the result of his trial would have been different,'" the court wrote. "That standard was legally correct."
Justice Ketanji Brown Jackson, a Joe Biden appointee, said she would have denied the state's petition. She did not explain her decision.
Source: Courthouse News Service














