Clark v. Sweeney

607 U. S. 7 (2025) · 11/24/25

The Fourth Circuit departed from the principle of party presentation and abused its discretion in granting a new trial.

A Maryland jury found Jeremiah Sweeney guilty of second-degree murder and other crimes. After those convictions were affirmed on direct appeal, Sweeney sought postconviction relief in state court. Sweeney argued, among other things, that his trial counsel was ineffective under Strickland v. Washington, 466 U. S. 668, 686, for failing to voir dire the jury to ensure that one juror's unauthorized crime-scene visit had not tainted the other jurors. The state court denied relief after a hearing. Sweeney then petitioned for a writ of habeas corpus under 28 U. S. C. § 2254 in Federal District…

Held: The Fourth Circuit transgressed the party-presentation principle by granting relief on a claim that Sweeney never asserted and that the State never had a chance to address. “In our adversarial system of adjudication, we follow the principle of party presentation.” United States v. Sineneng-Smith, 590 U. S. 371, 375. The parties “ `frame the issues for decision,' ” while the court serves as “ `neutral arbiter of matters the parties present.' ” Ibid. (quoting Greenlaw v. United States, 554 U. S. 237, 243). The Fourth Circuit's “radical transformation” of Sweeney's simple…