Clark v. Sweeney

607 U. S. ____ (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 several other crimes. Sweeney’s convictions were affirmed on appeal, and his bid for post- conviction relief in state court was unsuccessful. Sweeney sought habeas relief in Federal District Court, and that court, too, denied relief. But the Fourth Circuit reversed and ordered a new trial, relying on a claim that Sweeney never asserted. Because the Court of Appeals departed dramatically from the principle of party presentation, we reverse.

According to the State’s witnesses at trial, Jeremiah Sweeney was arguing one night with neighbors about stolen marijuana. He eventually opened fire, missing his intended targets but killing a bystander who was about 75 yards away. At issue during trial was whether Sweeney could have been the shooter given his location and the angle of the bullet wound.