Clark V Sweeney

Jeremiah Sweeney was convicted of second-degree murder after a Maryland jury found him guilty. During deliberations, Juror 4 visited the crime scene and informed the jury about it. The juror was dismissed and deliberations continued with 11 jurors. Sweeney's convictions were affirmed on appeal. The Fourth Circuit reversed, ordering a new trial based on claims Sweeney never asserted, citing extraordinary failures from juror to judge to attorney. The Supreme Court reversed the Fourth Circuit, holding that the appellate court departed dramatically from the principle of party presentation by granting relief on a claim Sweeney never asserted and that the State never had the chance to address.

The Supreme Court reversed the Fourth Circuit's decision in Clark v. Sweeney because the appellate court granted habeas relief on a claim that the petitioner never asserted. The Fourth Circuit had concluded that Sweeney's trial was marred by extraordinary failures from juror to judge to attorney, but Sweeney only raised an ineffective assistance of counsel claim in his federal habeas petition. The Court held that the Fourth Circuit's decision departed dramatically from the principle of party presentation, which requires courts to decide only the claims that parties present to them.

The Supreme Court reverses the Fourth Circuit's judgment that granted Sweeney a new trial based on a claim he never asserted, holding that the Court of Appeals departed from the principle of party presentation by deciding on an unasserted claim. The case is remanded for further proceedings on Sweeney's ineffective-assistance claim.

The Supreme Court granted the petition for certiorari, reversed the judgment of the Fourth Circuit, and remanded the case for further proceedings consistent with this opinion. The Fourth Circuit should analyze the ineffective-assistance claim that Sweeney asserted.

In the adversarial system of adjudication, courts follow the principle of party presentation. The parties frame the issues for decision, while the court serves as a neutral arbiter of matters the parties present. Courts call balls and strikes; they do not get a turn at bat. The Supreme Court reversed the Fourth Circuit for violating this principle by granting relief on a claim that Sweeney never asserted and that the State never had the chance to address. The Fourth Circuit had devised a new claim based on a 'combination of extraordinary failures from juror to judge to attorney' instead of ruling on Sweeney's actual claim of ineffective assistance of counsel. On remand, the Fourth Circuit should analyze the ineffective-assistance claim that Sweeney asserted under the Antiterrorism and Effective Death Penalty Act of 1996, with relief barred unless the state court's decision was contrary to or involved an unreasonable application of clearly established Federal law.

Antiterrorism and Effective Death Penalty Act of 1996