Clark v. Sweeney

Questions presented

SCOTUS records

QUESTIONS PRESENTED The Antiterrorism and Effective Death Penalty Act (AEDPA) prohibits federal courts from granting

Opinion summary

Etalia.ai summary of the majority opinion

A Maryland jury convicted Jeremiah Sweeney of second-degree murder and other crimes after a juror visited the crime scene on his own and was dismissed, leaving 11 jurors. Sweeney later sought federal habeas relief, arguing that his trial lawyer was ineffective for not asking to question the whole jury about possible taint from the juror’s visit. The district court denied relief, but the Fourth Circuit reversed on a different theory, saying a combination of failures by the juror, judge, and counsel violated Sweeney’s confrontation and impartial-jury rights. In a per curiam opinion, the Court reversed because the court of appeals violated the principle of party presentation by deciding a claim Sweeney had not raised and the State had not been able to address. The Court remanded for the Fourth Circuit to consider the ineffective-assistance claim Sweeney actually presented under the deferential AEDPA and Strickland standards.