Clark v. Sweeney: Federal habeas courts can’t grant relief on claims not raised by parties
By Greg Mermelstein, Deputy Director & General Counsel, Missouri Public Defender
Federal habeas courts cannot grant relief on claims the parties never raised because this violates the principle of party presentation, the U.S. Supreme Court held November 24, 2025, in Clark v. Sweeney.
Jeremiah Sweeney was convicted of various offenses in Maryland. His convictions were affirmed on appeal, and he was denied state postconviction relief.
On federal habeas review, he raised a claim of ineffective assistance of counsel on grounds that his trial counsel had failed to seek to ask all jurors about whether they were affected by one of the jurors’ unauthorized visit to the crime scene.
The district court denied relief.
The Fourth Circuit, however, granted relief but not on the ineffective-assistance claim. Instead, the Fourth Circuit ruled Sweeney’s trial was marred by a “combination of extraordinary failures from juror to judge to attorney” that deprived Sweeney of his rights to be confronted with witnesses against him and to trial by an impartial jury.
Holding
The Supreme Court reversed, in a per curiam opinion.
“In our adversarial system of adjudication, we follow the principle of party presentation”, the Court said. “The parties ‘frame the issues for decision,’ while the court serves as ‘neutral arbiter of matters the parties present’”.
“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”, the Court said.
“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”, the Court said.
“On remand, the Fourth Circuit should analyze the claim ineffective-assistance claim that Sweeney asserted”, the Court concluded.