Long v. Hooks, No. 18-6980 (4th Cir. 2020)Annotate this Case
The Fourth Circuit affirmed the district court's grant of the state's motion for summary judgment and rejected petitioner's claim that a state post-conviction court unreasonably applied Brady v. Maryland, 373 U.S. 83 (1963), when evaluating evidence disclosed to him for the first time thirty years after his trial. The court held that, although petitioner showed that the state court's summary conclusion misstated the burden of proof for Brady claims, that error did not entitle petitioner to habeas relief. In this case, the state court found the cumulative effect of any new evidence with any value was so minimal that it would have no impact on the outcome of the trial. The court held that the state court's reasonable finding supported the state court's decision that any newly disclosed evidence fell short of the kind of materiality that Brady required.