SCOTUS reverses COA order granting habeas relief because it relied on ground not raised by parties.
Terrence Clark v. Jeremiah Antoine Sweeney, USSC No. 25-52, 11/24/2025; Scotusblog page (with links to briefs and commentary)
SCOTUS reverses Fourth Circuit’s order granting habeas relief because the court relied on ground that was not presented by the parties.
During Jeremiah Sweeney’s trial in Maryland for second-degree murder, a juror “decided to check out the crime scene for himself.” (Slip op. at p. 1). The juror told the other jurors about his visit during deliberations, which was promptly reported to the trial court. The parties agreed not to declare a mistrial but to dismiss the juror and proceed with 11 jurors. Sweeney was convicted.
Sweeney argued on appeal in the Maryland state courts and in his federal habeas petition that his trial counsel was ineffective for not seeking to voir dire the entire jury. Sweeney’s conviction was affirmed in state court and by the federal district court. However, the Fourth Circuit Court of Appeals reversed the district court’s order denying Sweeney’s habeas corpus petition, “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 extraordinary 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.” (p. 2).
SCOTUS, in a per curiam opinion, reversed the Fourth Circuit’s order based on the principle of “party presentation” that is inherent to an adversarial system of justice where the parties “frame the issues for decision” and the court serves as “neutral arbiter of matters the parties present.” (p. 2). The Court held that 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.” (p. 3). Because the Fourth Circuit “departed so drastically from the principle of party presentation,” it abused its discretion. (p. 3).