Supreme Court reverses appeals court in Maryland attempted murder case, Jackson dissents alone
The Supreme Court slapped down a federal appeals court that had handed a convicted would-be killer a path back to trial, and only one justice objected.
Ketanji Brown Jackson dissented from the unsigned order reversing the lower court's ruling in the case of Charles Brandon Martin, a Maryland inmate serving a life sentence for shooting his girlfriend in the head. Jackson did not explain her disagreement.
According to Knewz.com, the rest of the Court found the appeals court had botched the legal standard so thoroughly that it warranted summary reversal. No oral arguments, no extended briefing. Just a clear correction.
The case itself is as ugly as they come. And the procedural history reveals something worth paying attention to: how many layers of the federal judiciary were willing to second-guess a state conviction on increasingly thin grounds before the Supreme Court stepped in.
The Crime
Martin was convicted of shooting Jodi Torok — his girlfriend — in the head. Prosecutors laid out a straightforward motive: the relationship soured when Torok learned she was expecting. Martin pushed her to terminate the pregnancy. She refused and told him she planned to seek child support.
Weeks later, a friend discovered Torok unconscious with a gunshot wound to the head.
The evidence at trial was considerable. A .380-caliber shell casing and bullet were recovered from the scene. Federal records confirmed Martin owned a .380-caliber semiautomatic handgun capable of firing that round. Investigators recovered a modified Gatorade bottle they believed may have functioned as a makeshift silencer. A single hair found on tape attached to the bottle could not be matched to 99.94 percent of North America's population — though experts could not rule Martin out.
Then there was the testimony from another girlfriend, who told the jury she saw Martin looking up gun silencers on his laptop before the shooting.
The jury convicted. Martin received a life sentence.
The Legal Odyssey
Martin's post-conviction argument centered on a forensic report analyzing five computers seized from his home. Prosecutors had not disclosed the report, and Martin argued this violated his due-process rights. The report, according to the case record, showed that keyword searches of the computers produced no results.
A state post-conviction court agreed and ordered a new trial. Maryland's intermediate appeals court reversed that order. Then Martin took his case to federal court — where a district judge granted him relief, and a divided federal appellate panel did the same.
That's four bites at the apple across two court systems before the Supreme Court finally called a halt.
The AEDPA Standard
The legal framework here matters. Under the Antiterrorism and Effective Death Penalty Act of 1996, federal courts can intervene in state convictions only if the state court decision was "contrary to, or involved an unreasonable application of, clearly established federal law," or rested on "an unreasonable determination of the facts." The bar is intentionally high. The challenger must show the state court was wrong so badly that every fair-minded jurist would disagree.
The Supreme Court found the federal appeals panel blew past that standard entirely. The unsigned opinion stated the lower panel "contravened these well-settled principles in two ways" — misreading the legal standard and concluding "that no fair-minded jurist could find the forensic report on the computer to be immaterial."
The Court was blunt about the strength of the prosecution's case:
"Based on all the evidence, a fair-minded jurist could easily conclude that disclosure of the forensic report on the laptop would not have made a difference."
The record, the Court found, contained "strong support" that Martin "would have been convicted" even if the forensic report had "severely impeached" the girlfriend's testimony about the silencer searches. The eyewitness testimony was one thread in a much thicker rope — the gun, the casing, the makeshift silencer, the hair, the motive.
Jackson Stands Alone
Justice Jackson's dissent came without explanation. The Court noted only that she would have denied the request to hear the case — meaning she wouldn't have touched it at all, leaving the appeals court's ruling intact and Martin's path to a new trial open.
No reasoning. No written opinion. Just a quiet signal of disagreement with the entire bench.
It's worth noting what Jackson was effectively endorsing by declining to act: a federal appellate panel overriding a state appellate court on a standard specifically designed to prevent exactly that kind of second-guessing. AEDPA exists because Congress recognized that federal habeas review was becoming an endless loop — a mechanism for relitigating state convictions until a sympathetic panel materialized. That is precisely what happened here, court by court, until the Supreme Court reversed the chain.
What This Says About Federal Overreach
The procedural history of this case is a miniature lesson in how the federal judiciary can erode state criminal convictions through sheer persistence. A state court convicted Martin. A state appeals court upheld the conviction. A state post-conviction court wobbled, but the state appellate court corrected it. Then the federal courts came in and did what AEDPA was written to prevent — treated a debatable state-court judgment as an unreasonable one.
The Supreme Court's unsigned, summary reversal sends a message: the standard means what it says. Federal courts do not get to substitute their judgment for the state court's simply because they might have weighed the evidence differently. The question is whether any fair-minded jurist could have reached the state court's conclusion. In this case, the answer was obvious enough that the Court didn't even need to hear arguments.
A woman was shot in the head. A jury weighed the evidence and convicted the man who did it. The system worked until a federal appeals panel decided it knew better.
Eight justices disagreed. One didn't bother to say why.




