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You know when there’s a chart in the procedural history section of a habeas case that you're going to need to buckle up. And so it is in the Fourth Circuit this week, where a Baltimore drug deal was broken up by cops and the purported seller threw a bag on the ground and made a run for it. The bag contained 10 grams of cocaine, and prosecutors rely on two chain-of-custody reports. But the reports have discrepancies, and one wasn't handed over until the second day of trial. That's a Brady violation and, accordingly, a habeas grant. Dissent: “Here we go again." The majority doesn't appropriately defer to state decision-making, and is just plain wrong.
The case is Moore v. State of Maryland, No. 24-6325 (4th Cir. 2026).
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