Ahmad Abouammo v. United States

The Supreme Court reversed the Fourth Circuit's decision granting federal habeas relief to Charles Brandon Martin, who was convicted in Maryland state court as an accessory before the fact in the attempted murder of his pregnant girlfriend, Jodi Torok. Martin argued that the State violated his rights under Brady v. Maryland by failing to disclose a forensic report about a laptop that could have been used to impeach a prosecution witness named Sheri Carter, who testified that Martin had used the laptop to research gun silencers. The Maryland appellate court found the undisclosed report was not "material" under Brady because there was no reasonable probability the trial outcome would have been different given the strength of the other evidence. The Fourth Circuit disagreed, concluding the state court had applied the wrong legal standard and that every fair-minded jurist would find the report material.

The Supreme Court held that the Fourth Circuit failed to apply the strict deference required by the Antiterrorism and Effective Death Penalty Act (AEDPA). Under AEDPA, federal courts may only overturn a state court's decision on a constitutional claim if it was contrary to, or an unreasonable application of, clearly established federal law — a standard far more demanding than simple disagreement. The Court found that the Maryland appellate court correctly stated and applied the Brady materiality test, and that federal courts cannot reject a state court's reasoning merely because its written opinion was not sufficiently detailed or "nuanced." The Court further held that given the strong evidence against Martin — including DNA linking him to a modified Gatorade bottle likely used as a homemade silencer, eyewitness testimony, motive evidence, and evidence of his gun ownership — a fair-minded jurist could easily conclude that disclosure of the laptop report would not have changed the verdict. The practical effect is that Martin's conviction stands and he is not entitled to a new trial.