The question
Whether the Fourth Circuit violated the party-presentation principle by granting a habeas petitioner a new trial on a constitutional claim he never raised.
Clark v. Sweeney
What the Court decided
The Court reversed the Fourth Circuit and remanded. Sweeney sought federal habeas relief on a single claim, that his trial counsel was ineffective under Strickland for not seeking to voir dire the entire jury after one juror made an unauthorized crime-scene visit. The Fourth Circuit instead ordered a new trial on Confrontation Clause and impartial-jury grounds that Sweeney never asserted and the State never had a chance to address. The Court held that granting relief on an unraised claim departed so far from the principle of party presentation as to be an abuse of discretion, and directed the Fourth Circuit on remand to address the ineffective-assistance claim Sweeney actually raised.
How the justices split
UnanimousPer curiam (unsigned)
Delivered by the Court
The Court held that the Fourth Circuit departed from the principle of party presentation by granting Sweeney a new trial on Confrontation Clause and impartial-jury grounds he never raised, rather than deciding the ineffective-assistance claim he actually asserted. Under the adversarial system the parties frame the issues and the court acts as a neutral arbiter of matters the parties present. Transforming Sweeney's ineffective-assistance claim into constitutional theories the State never had a chance to address was an abuse of discretion. On remand the Fourth Circuit must analyze the ineffective-assistance claim Sweeney raised.
How we know · 5 sourced claims
Sweeney sought federal habeas relief under 28 U.S.C. Section 2254 arguing his trial counsel was ineffective under Strickland for not seeking to voir dire the entire jury.
Source: syllabus, Held
The District Court denied relief, finding the state court's application of Strickland was not objectively unreasonable.
Source: syllabus, Held
The Fourth Circuit reversed and ordered a new trial on the ground that Sweeney was deprived of his rights to confrontation and to an impartial jury, rather than on the ineffective-assistance claim Sweeney asserted.
Source: syllabus, Held
The Court held that granting relief on a claim Sweeney never asserted and the State never had a chance to address transgressed the party-presentation principle and was an abuse of discretion.
Source: syllabus, Held
The Court reversed and remanded, directing the Fourth Circuit to analyze the ineffective-assistance claim Sweeney actually asserted.
Source: syllabus, Held