Clark v. Sweeney
No. 25-52 · Decided November 24, 2025 · reversed and remanded
Did the Fourth Circuit Court of Appeals violate the party-presentation principle by granting a new trial based on a legal claim that the respondent never asserted? The Fourth Circuit abused its discretion and violated the party-presentation principle by granting a new trial based on a claim the respondent never asserted.
ON PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
Parties — Petitioner: CLARK · Respondent: SWEENEY
Vote & lineupPer Curiam
Who prevailed — The petitioner prevailed in having the judgment of the Fourth Circuit reversed and the case remanded.
The question

Did the Fourth Circuit Court of Appeals violate the party-presentation principle by granting a new trial based on a legal claim that the respondent never asserted? Specifically, did the court exceed its role as a neutral arbiter by transforming a claim of ineffective assistance of counsel into a broader claim of constitutional failure? Does such a departure from the issues framed by the parties constitute an abuse of discretion?

Petitioner's argument
  • The Fourth Circuit transgressed the party-presentation principle by granting relief on a claim that the respondent never asserted.
  • The State was denied the opportunity to address the "combination of extraordinary failures" claim because it was not raised in the original petition.
  • The court's "radical transformation" of the respondent's simple ineffective-assistance claim constituted an abuse of discretion.
  • The court should have limited its review to the specific claim brought by the respondent.
Respondent's argument
  • not stated.
The decision
  • The Court held that the Fourth Circuit violated the "principle of party presentation" by granting relief on a claim that the respondent never asserted and the State never had the chance to address.
  • In the U.S. adversarial system, parties "frame the issues for decision," while the court serves as a "neutral arbiter of matters the parties present," citing *United States v. Sineneng-Smith*, 590 U. S. 371, 375 (2020) and *Greenlaw v. United States*, 554 U. S. 237, 243 (2008).
  • The Court reasoned that courts "call balls and strikes" and do not "get a turn at bat," citing *Lomax v. Ortiz-Marquez*, 590 U. S. 595, 599 (2020).
  • The Fourth Circuit's "radical transformation" of the respondent's claim departed so drastically from the party-presentation principle as to constitute an abuse of discretion, citing *Sineneng-Smith*.
  • On remand, the Fourth Circuit must analyze the actual ineffective-assistance claim under 28 U. S. C. § 2254(d), which bars relief unless the state court's decision was "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States."
  • The Court noted that when a state court has already adjudicated a *Strickland* claim, the federal analysis is "doubly deferential," citing *Dunn v. Reeves*, 594 U. S. 731, 739 (2021) and *Burt v. Titlow*, 571 U. S. 12, 15 (2013).
  • Under this standard, a federal court may grant relief only if "every 'fairminded jurist' would agree that every reasonable lawyer would have made a different decision," citing *Harrington v. Richter*, 562 U. S. 86, 101 (2011).