Brad Keith Sigmon v. Bryan Stirling, Commissioner, South Carolina Department of Corrections, et al.
1. Capital defendant Brad Sigmon presented additional mitigation evidence uncovered during a Martinez investigation that addressed the same general subject matter presented at the sentencing phase of trial in greater depth and detail. Did the Fourth Circuit, in a decision that widened an existing circuit split, violate this Court's directives on the Sixth Amendment's right to effective counsel when it rejected Sigmon's Martinez evidence as cumulative, and as a matter of law insubstantial, simply because it covered similar topics as those presented at trial?
2. In considering whether to grant an evidentiary hearing on a Martinez claim, does the requirement that evidence be substantial merely require a showing of some merit, as suggested by this Court, or must the reviewing court be convinced of a reasonable probability of a different outcome before allowing such a hearing?
Whether the Fourth Circuit violated this Court's directives on the Sixth Amendment's right to effective counsel when it rejected Sigmon's Martinez evidence as cumulative and insubstantial