The Supreme Court issued a per curiam decision in *Klein v. Martin* on January 26, 2026, reversing the Fourth Circuit Court of Appeals and reinforcing strict limitations on federal habeas relief for state prisoners. The case involved Charles Brandon Martin, who was convicted in Maryland court for the attempted murder of his girlfriend, Jodi Torok.
The Court's unsigned opinion emphasized that federal courts are "dutybound to comply with AEDPA," referring to the Antiterrorism and Effective Death Penalty Act of 1996. The law establishes strict standards that govern when federal courts can grant habeas relief to prisoners convicted in state court.
"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 Court wrote. "But federal courts are dutybound to comply with AEDPA."
The case represents the latest in a series of Supreme Court decisions strengthening AEDPA's restrictions on habeas relief. The Court cited several recent per curiam decisions where it granted summary relief when lower courts departed from AEDPA's requirements, including *Clark v. Sweeney* (2025), *Dunn v. Reeves* (2021), *Mays v. Hines* (2021), *Virginia v. LeBlanc* (2017), and *White v. Wheeler* (2015).
According to the opinion, Martin was convicted in Maryland court for attempting to murder Jodi Torok. The Court noted that "the evidence against him was strong" and that his conviction was affirmed on appeal. During state postconviction proceedings, an appellate court found that the state failed to disclose certain impeachment evidence favorable to Martin, though the complete details of this finding were not included in the available portion of the opinion.
The Fourth Circuit Court of Appeals apparently granted habeas relief to Martin, prompting the state to petition the Supreme Court for review. Christopher Klein, the Superintendent of the Department of Detention Facilities for Anne Arundel County, along with other state officials, sought to reverse the Fourth Circuit's decision.
The Supreme Court's per curiam reversal indicates that the justices found the Fourth Circuit exceeded its authority under AEDPA. Per curiam decisions are issued without oral argument and typically involve cases where the Court believes the law is well-established and the lower court's error is clear.
AEDPA, enacted in 1996, significantly restricts federal courts' ability to second-guess state court criminal convictions through habeas corpus petitions. The law requires federal courts to give substantial deference to state court factual findings and legal determinations. Federal courts can only grant habeas relief if the state court's decision was "contrary to" or involved an "unreasonable application of" clearly established federal law as determined by the Supreme Court.
The Supreme Court has consistently reinforced these limitations in recent years, frequently issuing per curiam reversals when lower federal courts grant habeas relief that the justices view as inconsistent with AEDPA's restrictive standards. These summary reversals send a strong message to lower courts about the narrow scope of federal habeas review.
The *Klein v. Martin* decision continues this trend of the Court emphasizing federal judicial restraint in habeas cases. By issuing the decision per curiam, the Court avoided the need for full briefing and oral argument, suggesting the justices viewed the Fourth Circuit's error as straightforward under existing precedent.
For practitioners in the habeas corpus field, the decision serves as another reminder of the high bar for obtaining federal relief for state prisoners. The Court's citation to its recent string of similar per curiam reversals demonstrates its continued commitment to enforcing AEDPA's limitations strictly.
The case also highlights the ongoing tension between federal and state authority in criminal justice. While AEDPA was designed to limit federal interference with state court convictions, critics argue that overly restrictive application can prevent correction of genuine constitutional violations.
The decision was docketed as No. 25-51 and represents one of the Court's first major habeas corpus rulings of 2026. As a per curiam opinion, it does not identify which justices, if any, may have dissented from the majority's decision to reverse the Fourth Circuit.
The ruling will likely influence how federal district courts and courts of appeals approach similar habeas petitions from state prisoners, reinforcing the message that AEDPA's standards must be applied rigorously even when federal judges might personally disagree with state court outcomes.