SCOTUS reverses decision granting new homicide trial and accepts cert. to review geofence warrants; while Justice Jackson dissents from shutting courthouse door to prison inmates.
In its January 2026 orders, SCOTUS reminds the Fourth Circuit about AEDPA deference in reversing decision ordering a new trial and grants certiorari to determine whether a geofence warrant violates the Fourth Amendment, while Justice Jackson dissents from banning frequent inmate filers from commencing a case without paying the filing fee.
Klein v. Martin, USSC No. 25-51, 1/26/2026; Scotusblog page (with links to briefs and commentary)
Klein was convicted in Maryland state court of attempted murder and assault with the intent to commit murder after his girlfriend was shot in her home. In addition to ballistic and DNA evidence that incriminated Klein, several witnesses testified that Klein made a silencing device for the gun that was used to shoot the victim. Klein’s former girlfriend testified that she saw Klein searching for gun silencers on his laptop computer. After trial, the state disclosed a forensic report for Klein’s computers, which showed that a keyword search for words such as “handgun,” “silencer,” or “homemade silencer” yielded no hits.
Klein’s argument that the state violated his due process right by failing to disclose the forensic report was denied by the Maryland appeals courts, but a new trial was ordered after his federal habeas petition was granted by the district court and affirmed by a divided Fourth Circuit. The Fourth Circuit found that the state court did not correctly apply the standard to determine whether the undisclosed exculpatory evidence was material to Klein’s conviction. Although the state court cited the correct rule on materiality and claimed to apply it, the Fourth Circuit determined it applied a sufficiency of the evidence test that SCOTUS previously rejected. (pp. 6-7).
The Antiterrorism and Effective Death Penalty Act (AEDPA) allows a federal court to grant habeas relief from a state conviction only when the state court’s decision was “contrary to, or involved an unreasonable application of, clearly established Federal law as determined by the Supreme Court, or was based on an unreasonable determination of the facts. 28 U.S.C. § 2254(d). The Court emphasized that a state prisoner needs to show “far more” than clear error and must establish that the state court “blundered so badly that every fairminded jurist would disagree with the decision.” (pp. 7-8).
When the Fourth Circuit found that the state appellate court applied the wrong rule because it did not discuss certain evidence that undermined the state’s case and that its analysis was insufficiently “nuanced,” SCOTUS concluded, its “holding was a basic misapplication of AEDPA, which bars federal courts from imposing opinion-writing standards on state courts and demands that the state-court decision be given the benefit of the doubt.” (pp. 9-10). SCOTUS also concluded the Fourth Circuit “went astray” when it determined every fairminded jurist would find the undisclosed forensic report material in light of the strength of the DNA and ballistic evidence. The Court cautioned that faithful application of AEDPA “sometimes puts federal districts court 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.” (p. 1).
Chatrie v. United States, USSC No. 25-112, 1/16/2026; Scotusblog page (with links to briefs and commentary)
A geofence warrant allows law enforcement to obtain the identities of cell phone users in a particular location at a particular time from the cell phone service provider. Here, authorities obtained a geofence warrant requiring Google to disclose location data for every device within 150 meters of where a bank robbery occurred, which led to the petitioner’s conviction for armed robbery.
Chatrie argues that the geofence warrant is not sufficiently particular to comply with the Fourth Amendment. SCOTUS granted certiorari to resolve a split among the federal circuit courts of appeals and state courts regarding whether the constitutionality of geofence warrants.
Howell v. Circuit Court of Indiana, USSC No. 25-5557, 1/20/2026
Justice Jackson dissented from the Court’s order prohibiting an Indiana state prison inmate from filing any further petitions for certiorari in noncriminal matters without paying the filing fee of $300. Noting that Howell filed only six petitions in fourteen years, Justice Jackson considered the benefit of reducing the Court’s administrative burden outweighed by the cost of closing a prisoner’s access to judicial review. More broadly, Justice Jackson would not apply the filing bar for frequent “frivolous” filers to any prisoner requesting to proceed in forma pauperis.