Case Summaries: Fourth Circuit Court of Appeals - January 2020

This post summarizes criminal and related decisions published by the Fourth Circuit Court of Appeals in January, 2020. Decisions of interest to state practitioners will be posted on a monthly basis. Previous Fourth Circuit case summaries are available here. Divided panel affirms denial of habeas relief; state court’s determination of Brady claims was reasonable despite misstatement of Brady standard Long v. Hooks, ___ F.3d ___, 2020 WL 89109 (Jan. 8, 2020). In this habeas case from the Middle District of North Carolina, the petitioner was convicted of rape and burglary in 1976 and sentenced to two life sentences in state court. He appealed and sought state and federal post-conviction relief without success. In subsequent state post-conviction proceedings in 2005, “dozens of documents” relating to the case were disclosed by the State, including documentation relating to forensic testing from the State Bureau of Investigation (“SBI”), the “master” investigative file, and the medical records of the victim. The forensic reports showed hair samples from the defendant failed to match hairs on the crime scene and that clothing items recovered from the defendant did not match fiber samples recovered from the scene. A latent shoeprint from the scene was compared to the defendant’s shoes and found to be inconclusive. Burned matches at the scene compared to matches found in the defendant’s car were similarly inconclusive. The case file showed that an officer had requested testing on a shoeprint from the scene, as well as on clothing and other items from the defendant (although an [...]