Clark v. Sweeney

Summary

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

Text

PRELIMINARY PRINT 
Volume 607 U. S. Part 1 
Pages 7–10 
OFFICIAL REPORTS 
OF 
THE SUPREME COURT 
November 24, 2025 
REBECCA A. WOMELDORF 
reporter of decisions 
Page Proof Pending Publication
NOTICE: This preliminary print is subject to formal revision before 
the bound volume is published. Users are requested to notify the Reporter 
of Decisions, Supreme Court of the United States, Washington, D. C. 20543, 
[email protected], of any typographical or other formal errors.

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OCTOBER TERM, 2025 7 
Syllabus 
CLARK v. SWEENEY 
certiorari to the united states court of appeals for 
the fourth circuit 
No. 25–52. Decided November 24, 2025 
A Maryland jury found Jeremiah Sweeney guilty of second-degree murder 
and other crimes. After those convictions were affrmed on direct ap-
peal, Sweeney sought postconviction relief in state court. Sweeney ar-
gued, 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 Court, again arguing that his trial counsel was 
ineffective for not seeking to voir dire the entire jury. The District 
Court denied relief, concluding that the state court's application of 
Strickland was not objectively unreasonable. The Fourth Circuit re-
versed in an unpublished opinion and ordered a new trial. Instead of 
addressing the ineffective-assistance claim that Sweeney asserted, the 
Fourth Circuit held that Sweeney's trial had been marred by a “combi-
nation of extraordinary failures from juror to judge to attorney” that 
deprived Sweeney of his right to be confronted with the witnesses 
against him and to be tried by an impartial jury. App. to Pet. for Cert. 
22a, 29a. 
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 mat-
ters the parties present.' ” Ibid. (quoting Greenlaw v. United States, 
554 U. S. 237, 243). The Fourth Circuit's “radical transformation” of 
Sweeney's simple ineffective-assistance claim “departed so drastically 
from the principle of party presentation as to constitute an abuse of 
discretion.” Sineneng-Smith, 590 U. S., at 380, 375. On remand, the 
Fourth Circuit should analyze the ineffective-assistance claim that 
Sweeney asserted. See Dunn v. Reeves, 594 U. S. 731, 739 (per 
curiam). 
Certiorari granted; reversed and remanded.

8 CLARK v. SWEENEY 
Per Curiam 
Per Curiam. 
A Maryland jury found Jeremiah Sweeney guilty of second-
degree murder and several other crimes. Sweeney's convic-
tions were affrmed on appeal, and his bid for postconviction 
relief in state court was unsuccessful. Sweeney sought ha-
beas relief in Federal District Court, and that court, too, de-
nied 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. 
I 
According to the State's witnesses at trial, Jeremiah 
Sweeney was arguing one night with neighbors about stolen 
marijuana. He eventually opened fre, 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. 
After the State rested its case, Juror 4's curiosity got the 
best of him, and he decided to check out the crime scene for 
himself. Shortly after jury deliberations began, Juror 4 told 
the jury about his visit, and the jury promptly reported his 
visit to the court. The parties conferred and eventually 
agreed that rather than declare a mistrial, the court would 
dismiss Juror 4 and deliberations would proceed with 11 ju-
rors. Sweeney was convicted, and his convictions were af-
frmed on direct appeal. 
Sweeney later fled a petition for postconviction relief in 
state court. He argued, among other things, that his trial 
counsel was ineffective under Strickland v. Washington, 466 
U. S. 668, 686 (1984), for not seeking to voir dire the entire 
jury to ensure that no other juror was tainted by Juror 4's 
unauthorized crime-scene visit. The state court denied re-
lief after a hearing. With the help of appointed counsel, 
Sweeney then petitioned for a writ of habeas corpus under 28 
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Cite as: 607 U. S. 7 (2025) 9 
Per Curiam 
U. S. C. § 2254 in Federal District Court. As in state court, 
Sweeney argued that his trial counsel was ineffective for not 
seeking to voir dire the entire jury. The District Court de-
nied Sweeney's petition, concluding that the state court's ap-
plication of Strickland was not objectively unreasonable. 
In an unpublished opinion, the Fourth Circuit reversed— 
but not on the ineffective-assistance claim that Sweeney 
brought. Instead, the Fourth Circuit declared that 
Sweeney's trial was marred by a “combination of extraordi-
nary failures from juror to judge to attorney” that deprived 
Sweeney of his right to be confronted with the witnesses 
against him and his right to trial by an impartial jury. App. 
to Pet. for Cert. 22a, 29a. That error, the Court of Appeals 
concluded, entitled Sweeney to a new trial. Judge Quattle-
baum dissented, criticizing the majority for “fout[ing]” tradi-
tional principles of party presentation. Id., at 99a–103a. 
II 
“In our adversarial system of adjudication, we follow the 
principle of party presentation.” United States v. Sineneng-
Smith, 590 U. S. 371, 375 (2020). The parties “ `frame the 
issues for decision,' ” while the court serves as “ `neutral arbi-
ter of matters the parties present.' ” Ibid. (quoting Green-
law v. United States, 554 U. S. 237, 243 (2008)). To put it 
plainly, courts “call balls and strikes”; they don't get a turn 
at bat. Lomax v. Ortiz-Marquez, 590 U. S. 595, 599 (2020). 
The Fourth Circuit transgressed the party-presentation 
principle by granting relief on a claim that Sweeney never 
asserted and that the State never had the chance to address. 
Sweeney asserted “one, and only one,” claim in his federal 
habeas petition: that his counsel was ineffective for failing to 
investigate whether other jurors had been prejudiced by 
Juror 4's crime-scene visit. App. to Pet. for Cert. 53a (Quat-
tlebaum, J., dissenting). Instead of ruling on that claim, the 
Fourth Circuit devised a new one, based on a “combination 
of extraordinary failures from juror to judge to attorney.” 
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10 CLARK v. SWEENEY 
Per Curiam 
Id., at 22a. The Fourth Circuit's “radical transformation” of 
Sweeney's simple ineffective-assistance claim “departed so 
drastically from the principle of party presentation as to con-
stitute an abuse of discretion.” Sineneng-Smith, 590 U. S., 
at 380, 375. We accordingly reverse the judgment of the 
Fourth Circuit and remand the case for further proceedings. 
On remand, the Fourth Circuit should analyze the 
ineffective-assistance claim that Sweeney asserted. Under 
the Antiterrorism and Effective Death Penalty Act of 1996, 
relief is barred unless the state court's decision was “con-
trary to, or involved an unreasonable application of, clearly 
established Federal law, as determined by the Supreme 
Court of the United States.” 28 U. S. C. § 2254(d). When 
assessing a Strickland claim that a state court has already 
adjudicated, the “analysis is `doubly deferential.' ” Dunn v. 
Reeves, 594 U. S. 731, 739 (2021) (per curiam ) (quoting Burt 
v. Titlow, 571 U. S. 12, 15 (2013)). “[A] federal court may 
grant relief only if every `fairminded jurist' would agree that 
every reasonable lawyer would have made a different deci-
sion.” 594 U. S., at 739–740 (quoting Harrington v. Richter, 
562 U. S. 86, 101 (2011)). 
The petition for certiorari is granted, the judgment of the 
Fourth Circuit is reversed, and the case is remanded for fur-
ther proceedings consistent with this opinion. 
It is so ordered.

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Reporter’s Note 
The attached opinion has been revised to refect the usual publication 
and citation style of the United States Reports. The revised pagination 
makes available the offcial United States Reports citation in advance of 
publication. The syllabus has been prepared by the Reporter of Decisions 
for the convenience of the reader and constitutes no part of the opinion of 
the Court. Other revisions may include adjustments to formatting, cap-
tions, citation form, and any errant punctuation. The following additional 
edits were made: 
None

Retrieval chunks

• #1

  PRELIMINARY PRINT Volume 607 U. S. Part 1 Pages 7–10 OFFICIAL REPORTS OF THE SUPREME COURT November 24, 2025 REBECCA A. WOMELDORF reporter of decisions Page Proof Pending Publication NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to not…

• #2

  554 U. S. 237, 243). The Fourth Circuit's “radical transformation” of Sweeney's simple ineffective-assistance claim “departed so drastically from the principle of party presentation as to constitute an abuse of discretion.” Sineneng-Smith, 590 U. S., at 380, 375. On remand, the Fourth Circuit should analyze the in…

• #3

  U. S. C. § 2254 in Federal District Court. As in state court, Sweeney argued that his trial counsel was ineffective for not seeking to voir dire the entire jury. The District Court de- nied Sweeney's petition, concluding that the state court's ap- plication of Strickland was not objectively unreasonable. In an un…

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  Fourth Circuit and remand the case for further proceedings. On remand, the Fourth Circuit should analyze the ineffective-assistance claim that Sweeney asserted. Under the Antiterrorism and Effective Death Penalty Act of 1996, relief is barred unless the state court's decision was “con- trary to, or involved an un…