Clark v. Sweeney

Summary

The Supreme Court held that the Fourth Circuit violated the party-presentation principle by granting habeas relief on a claim that the petitioner had not asserted and the State had not addressed. The Court reversed and remanded for the Fourth Circuit to consider the petitioner’s actual ineffective-assistance-of-counsel claim under the deferential standards governing federal habeas review.

Holdings

1. The Fourth Circuit abused its discretion by transforming Sweeney's ineffective-assistance claim into a different claim concerning a combination of failures by the juror, judge, and attorney, because the new claim was neither asserted by Sweeney nor addressed by the State.
2. The Fourth Circuit must analyze the ineffective-assistance claim Sweeney actually asserted under AEDPA's deferential standard and the doubly deferential standard applicable to a state-court-adjudicated Strickland claim.

Questions Presented

1. Whether the Fourth Circuit violated the party-presentation principle and abused its discretion by granting habeas relief on a claim that Sweeney had not asserted and that the State had not had an opportunity to address.
2. What standard the Fourth Circuit must apply on remand to Sweeney's asserted ineffective-assistance-of-counsel claim under 28 U.S.C. § 2254(d) and Strickland.

Disposition

reversed_and_remanded