On trial in 2007 for a triple murder, Michael Wayne Reynolds saw his ex-girlfriend point her finger against him as the perpetrator. But what he didn't know until years later was that the woman, Adrian Marcella "Marcie" West, allegedly had a deal with prosecutors.

In exchange for leniency over drug crimes she had been charged with — but not yet convicted — including several felonies, West identified Reynolds as the person who, in the early hours of May 25, 2003, brutally killed Charles Martin III, his wife, Melinda, and their 8-year-old daughter Savannah in their Gadsden, Alabama, home.

Asked by Reynolds' defense attorney at trial if she had any agreement with the law in return for her testimony, West said no — and the prosecutors failed to correct her. An Etowah County jury ultimately convicted Reynolds of murder and recommended a death sentence. The judge obliged.

In the years following his conviction, Reynolds, who continues to profess his innocence, has argued that West's denial fits squarely into the type of information that could have helped him convince his jury that she couldn't be trusted, and that he didn't kill the Martins.

The case against Reynolds raises fundamental constitutional concerns — such as withheld evidence, prosecutorial misconduct and ineffective counsel — that strike at the core of the ability of prisoners to access federal courts to challenge their conviction, sentences or confinement on constitutional grounds, a process known as habeas corpus.

What's more, Reynolds' case exposes a deep ideological rift in the way federal courts defer to state court rulings while examining due process challenges.

Thursday evening, nearly 22 years after Reynolds entered Alabama death row, attorneys with BakerHostetler working pro bono took his case to the U.S. Supreme Court, filing a petition for certiorari that urged the justices to weigh in on his quest for due process.

"This is about justice for our client, who's never had his day in court on one of his fundamental constitutional claims," Patrick T. Campbell, a BakerHostetler partner, told Law360. "It's not justice if the person who is convicted of the crime is not the one who did it and has been convicted under a process that doesn't afford the basic constitutional protections that all criminal defendants should be afforded. Families of victims, too, deserve to know that the criminal justice system is working properly."

The Supreme Court ruled in 1963's Brady v. Maryland  that under the Constitution, prosecutors are obligated to turn over to defense attorneys all potentially exculpatory evidence in a case. In a later ruling, Giglio v. United States , the high court clarified that the Brady principle also applied to information that could be used to impeach prosecution witnesses.

In post-conviction proceedings, Reynolds repeatedly argued in court that West's denial of having made a deal with prosecutors — an assertion a federal appeals court would later find suspicious — violated his right to due process.

But Alabama state courts issued rulings denying him an evidentiary hearing on those claims, and federal courts gave deference to those decisions, citing federal habeas law.

Under the Antiterrorism and Effective Death Penalty Act of 1996, or AEDPA, people in custody have very limited access to habeas corpus.

Reynolds tried unsuccessfully to use that process. His petition for habeas corpus filed in 2018 was rejected first by a federal district court, then by the U.S. Court of Appeals for the Eleventh Circuit.

In his certiorari petition filed Thursday, Reynolds asked the high court to review the Eleventh Circuit's denial of habeas relief, specifically concerning his claim under the Brady and Giglio rulings, and the lack of an evidentiary hearing in state court.

"This case exposes the exact conflict of whether the federal habeas court should afford deference to the state court without determining if that factfinding was complete," he said in the petition.

Seanna R. Brown of BakerHostetler told Law360 that judges and prosecutors who favor the death penalty often say prisoners are afforded multiple opportunities — in post-conviction proceedings and through state and federal habeas corpus — to argue for their innocence, or even just due process.

But in practice, Brown said, because of AEDPA restrictions, prisoners never have a real chance to challenge a conviction unless they're granted a full evidentiary hearing where they get to present evidence and call witnesses.

"It's all a little bit of a sham," she said. "The statutory scheme is like 'Dante's Inferno,' where each layer builds on one another to ensure that petitioners have no way out."

Gruesome Killings and a Key Witness


All three members of the Martin family were stabbed to death. Melinda Martin's father, Jerry Veal, discovered the crime when he found their house burned. Inside were their bodies, which appeared to have been doused in gasoline and set ablaze​.

Early on, investigators looked to robbery as the likely motive after noting that Melinda Martin's purse and the family's cordless phone were missing from the home​. They initially pursued Charles Martin's nephew, Chad Martin, as a suspect. At first, the nephew declined being involved. But in a second statement, Chad Martin confessed to committing one of the murders, telling police that he and two friends, John Langley and John Zook, had killed the Martins.

According to the confession, which was not memorialized in any signed official statement but was detailed in two police reports, Zook stabbed Charles Martin after he refused to give them any drugs. Langley then followed Melinda Martin into the hallway and stabbed her to death. Langley then told Chad Martin to kill Savannah.

"She just looked at me with those big brown eyes wide open," Chad Martin told police of the moment before he stabbed the girl, according to the police reports.

After Chad Martin recanted that confession days later, the heat turned to Reynolds, then 30 years old and a friend of the Martins who had been with them that night. West eventually emerged as a key witness in the case.

Reynolds was charged with five counts of capital murder — one for each victim, plus counts for murder in the course of a robbery and for murder of a child under 14 — and tried in Etowah County in October 2007.

The prosecution's case relied heavily on the testimony of West, who said she drove Reynolds to the Martins' home on the night of the crime. According to her testimony, Reynolds told West that they were going there "to get some money," which she took to mean that they were going to rob Charles Martin, although he and Reynolds were good friends.

Most crucially, West said on the stand that she witnessed Reynolds attack the family. She testified that she saw Reynolds stab Melinda Martin while Savannah was there, and even accidentally stab West's own arm when she tried to intervene​. "Melinda was bent over, and he was stabbing her," West testified. "I was trying to make him quit."

According to West, Reynolds told her to take the family's cordless phone and Melinda Martin's purse and go wait in their car, and she complied out of fear. He then returned to the house and set it on fire before they fled, trial transcripts show.

Because West was the only purported eyewitness to the crimes for which Reynolds was charged, her testimony was crucial in securing his conviction. And during her cross-examination, West denied having entered any deal with the district attorney's office prosecuting Reynolds.

"Have you made any deals with the district attorney's office for your testimony today?" Paul R. Roberts II, one of the attorneys who represented Reynolds at trial, asked her.

"No, sir."

Marcus Reid, one of Reynolds' prosecutors, said at the sentencing hearing that no agreement was ever made with West.

"She absolutely has asked nothing of us in exchange for her cooperation. We told her there was no deal. And there was no deal," Reid said, according to a transcript of the hearing.

After testifying, three of West's pending drug charges were dismissed. She pled guilty to distribution and hindering prosecution and was sentenced on two charges to 20 years of imprisonment, running concurrently, split to three years, followed by five years' probation. Six months into her sentence, the state recommended suspending the remainder and placing her on probation, leading to her immediate release.

Reynolds' attorneys argue the leniency was part of a concealed deal. Years after the trial, Reynolds' legal team obtained a memo from West's former attorney suggesting there had been an understanding with the state for leniency. When Reynolds raised this in his post-conviction petition, the court did not allow live testimony or cross-examination. Instead, the court relied on affidavits, including one from West, reaffirming that no deal existed, and one from Reid denying any agreement.

The Etowah County District Attorney's Office, which prosecuted both Reynolds and West, declined to comment.

Roberts declined to comment about Reynolds' habeas case.

"It will run its course the way it needs to," he said.

A 'Brutal' Childhood

Reynolds grew up poor in what a social worker hired to present mitigating evidence at his trial called "a brutal and neglectful upbringing." His father was an alcoholic who beat his wife and children, routinely whipping them with his belt. His mother, who was overweight and diabetic, watched soap operas all day and did not engage the children — Reynolds and his three siblings.

When Reynolds was just a toddler, his father kicked him down their home's stairs. As his parents did not seek medical care for several days, Reynolds developed an infection. Eventually, his paternal aunt and uncle were called, and they took him to the emergency room, where it was discovered that the child had a broken collarbone.

As a teenager whose parents hardly ever knew where he was at any given time, Reynolds dropped out of school after seventh grade. He held steady jobs for years and was described as a compassionate person and a caring father to the child he had from his second marriage. But his life took a turn for the worse when he became addicted to drugs, in particular methamphetamine and crack cocaine.

Around the time the Martins were murdered, Reynolds was leading a disorderly life characterized by drug abuse, racking up criminal charges for stealing, breaking into cars, and for possessing and dealing drugs — though none of these offenses resulted in criminal convictions.

Throughout the years of his incarceration on death row, Brown said, Reynolds has developed an interest for art, and produced several drawings made with supplies he has received from outside.

"I find Michael to be a very curious human," she said, adding that she noted what she described as a "boyish quality" that predisposes him to making harmless jokes.

"He definitely likes to get a laugh," Brown said. "He's very social."

Habeas Proceedings

After being denied a retrial, having his conviction upheld by the Alabama Court of Criminal Appeals, and with the state's Supreme Court declining to hear his case, Reynolds petitioned the U.S. Supreme Court in May 2013 as part of his direct appeal, unsuccessfully.

Reynolds then filed a motion in Etowah County Circuit Court — the same one where he was convicted and sentenced — seeking post-conviction relief and an evidentiary hearing on his claims that his prosecutors had withheld favorable evidence from the defense, and that his trial counsel was ineffective. Reynolds faulted his counsel for failing to secure the admission of Chad Martin's confession and conduct a thorough mitigation investigation.

Through that state habeas process, which is governed by the state's "Rule 32," Reynolds sought to produce evidence of prosecutorial wrongdoing, but the court shut down his discovery requests as well as his broader effort to challenge his conviction without holding an evidentiary hearing.

Reynolds fought on, and in 2015, the state mid-level court — the Alabama Court of Criminal Appeals — ordered the trial court to hear the prisoner's claims under Brady and Giglio, either by conducting an evidentiary hearing or by looking at evidence submitted to the court.

The trial court never held an evidentiary hearing. Instead, it gave Reynolds only 20 days to engage in discovery and submit the evidence — even though state court rules allowed prosecutors 30 days to respond to document requests. The court ultimately sank Reynolds' discovery efforts, saying it believed that the prisoner had received all exculpatory evidence. And without holding an evidentiary hearing, the court ruled that Reynolds had failed to prove the Brady and Giglio violations by a preponderance of the evidence.

After exhausting his recourse in state courts, Reynolds filed his first federal habeas corpus petition Feb. 9, 2018, represented by BakerHostetler attorneys, including Brown, and attorneys with Lightfoot Franklin & White LLC, a Birmingham, Alabama-based firm.

In the habeas petition, Reynolds' attorneys zeroed in on the alleged Brady and Giglio violations, and argued that Alabama state courts never gave him a real chance to develop a record of potentially exculpatory evidence.

"Throughout the entire state post-conviction proceeding, Mr. Reynolds was never permitted to take adequate discovery or provided an evidentiary hearing at which he could have supported the allegations in his amended Rule 32 petition with evidence," the petition said.

In addition, Reynolds argued that there were issues with the physical evidence, such as the failure to find blood on the floorboards of the car where the alleged murder weapons were placed, poking holes in West's testimony​. Reynolds also said that the prosecution criticized him for not coming forward to talk to the police, potentially leading his jury to infer guilt based on the exercising of his constitutional rights.

Reynolds again argued his trial counsel was ineffective, particularly for failing to investigate and present key exculpatory evidence, including the retracted confession by Chad Martin, which could have cast doubt on Reynolds' involvement in the murder.

After lengthy proceedings, U.S. District Judge R. David Proctor issued a memorandum opinion March 25, 2022, calling Reynolds' claims "insufficiently pleaded" and denying his habeas corpus petition in its entirety. The court denied Reynolds' request for discovery and an evidentiary hearing, finding that the state court record was sufficient and that Reynolds had not met the high bar for relief under AEDPA.

On appeal, a panel of the Eleventh Circuit ultimately affirmed the lower court's denial of habeas on Oct. 7, 2024. Although acknowledging during oral arguments that West had received a "sweetheart deal" that "stinks to high heaven," the court ruled that Reynolds' Brady and Giglio claims were insufficiently supported by evidence from discovery. On Dec. 4, the same court of appeals then denied Reynold's request for a hearing before the full bench.

Reynolds was left with no other choice than to petition the U.S. Supreme Court.

Turning Again to the U.S. Supreme Court

In the certiorari petition filed Thursday, Reynolds' attorneys said there is an "intractable circuit split" whether and how to review the state court fact-finding processes under a specific provision of AEDPA — Section 2254(d)(2) of Title 28 of the U.S. Code — which allows federal courts to review those processes when they resulted in "unreasonable" determinations.

In the U.S. Court of Appeals for the Ninth Circuit, the factual findings of a state court based on a defective fact-finding process is deemed unreasonable, and so federal courts have the power to review from scratch the claims involved in those findings.

In the 2004 ruling Taylor v. Maddox , in particular, the Ninth Circuit held that when a state court fails to grant a petitioner an evidentiary hearing on the credibility of witnesses, or ignores evidence that supports a prisoner's claim, the fact-finding process is flawed. Reynolds says in the petition that the Sixth and Seventh circuits follow a similar rule.

The Fifth Circuit's approach, meanwhile, is way more restrictive. The court's 2001 ruling in Valdez v. Cockrell held that Congress intended for AEDPA's deference to state court fact-finding decisions to be nearly absolute, regardless of whether a prisoner has received a "full and fair" hearing in state court. The First, Third and Fourth circuits follow this approach.

The Eleventh Circuit, where Reynolds' case has played out, has not taken a firm position on either side of the spectrum.

Urging the justices to endorse the Ninth Circuit rule, Reynolds' attorneys argued that if federal courts aren't allowed to probe the reasonableness of state court processes, prisoners' due process rights are violated.

In their petition, the attorneys said that disparate outcomes among federal courts of appeals have "life-and-death ramifications" for habeas petitioners.

"Because the split remains, habeas petitioners will have different standards applied to their claims based not on the statutory language but on the vagaries of geography," the attorneys said. "This Court should intervene and resolve this important question."

The attorneys also urged the court to address an additional disharmony among courts: whether another AEDPA provision — Section 2254(e)(1) of Title 28 of the U.S. Code —that places on habeas petitioners the burden to show by "clear and convincing evidence" that state court determinations were wrong in their cases, is a prerequisite for obtaining habeas review under (d)(2).

The Ninth Circuit, again, has emerged as the most friendly to prisoners, holding that (e)(1) is not a requirement when a prisoner files a habeas challenge "based entirely on the state record." The Eleventh Circuit has rejected that view, effectively conflating the two provisions into one, Reynolds' attorneys said.

"The Eleventh Circuit has created an almost insurmountable barrier to questioning whether a state factual determination was unreasonable," they wrote in the petition.

Brown, who spoke with Reynolds recently, described him generally in "pretty good spirits" and "even-tempered."

In an email to Law360, Brown and Campbell said their client's case goes beyond him.

"Defendants, such as Michael and the thousands of other habeas petitioners every year, should not be deprived of their life without an evidentiary hearing, a full examination of the facts and evidence of the constitutional violation. And it should not depend on what court the petitioner is in," the attorneys said. "That's why we think this is such an important case for the Supreme Court to take."

--Editing by Orlando Lorenzo.

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