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|summary=The Fourth Circuit erred in granting habeas relief to Sweeney based on a claim of constitutional error that he had never alleged. |
|summary=The Fourth Circuit erred in granting habeas relief to Sweeney based on a claim of constitutional error that he had never alleged. |
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Sweeney was convicted of multiple crimes in state court. At trial, a juror unlawfully visited the crime scene. That juror reported the findings to the jury. The judge removed that delinquent juror, but the judge didn’t call a mistrial and Sweeney’s counsel did not [[voir dire]] the remaining jurors to assess the effect of the delinquent juror’s actions on them. This failure to [[voir dire]] formed the basis of a habeas petition in Federal District Court, which denied relief under [[Strickland]]. Sweeney only raised one issue in federal court, the ineffective assistance of his counsel at trial. Sweeney appealed. The Fourth Circuit granted relief on the basis of multiple errors committed by judge, jury and attorneys. None of those errors was ever raised, and Clark had no opportunity to respond. Therefore, the Supreme Court held that the Fourth Circuit violated the ”party presentation principle”<ref>Little, Rory (January 7, 2026). January’s criminal law arguments – and is “party presentation” morphing into a court-controlling rule? SCOTUSblog. Retrieved February 5, 2026, from https://www.scotusblog.com/2026/01/januarys-criminal-law-arguments-and-is-party-presentation-morphing-into-a-court-controlling-rule/</ref>. See [[United_States_v._Sineneng-Smith|US v. Sineneng-Smith]] |
Sweeney was convicted of multiple crimes in state court. At trial, a juror unlawfully visited the crime scene. That juror reported the findings to the jury. The judge removed that delinquent juror, but the judge didn’t call a mistrial and Sweeney’s counsel did not [[voir dire]] the remaining jurors to assess the effect of the delinquent juror’s actions on them. This failure to [[voir dire]] formed the basis of a habeas petition in Federal District Court, which denied relief under [[Strickland]]. Sweeney only raised one issue in federal court, the ineffective assistance of his counsel at trial. Sweeney appealed. The Fourth Circuit granted relief on the basis of multiple errors committed by judge, jury and attorneys. None of those errors was ever raised, and Clark had no opportunity to respond. Therefore, the Supreme Court held that the Fourth Circuit violated the ”party presentation principle”<ref>Little, Rory (January 7, 2026). January’s criminal law arguments – and is “party presentation” morphing into a court-controlling rule? SCOTUSblog. Retrieved February 5, 2026, from https://www.scotusblog.com/2026/01/januarys-criminal-law-arguments-and-is-party-presentation-morphing-into-a-court-controlling-rule/</ref>. See [[United_States_v._Sineneng-Smith|US v. Sineneng-Smith]] |
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Latest revision as of 01:10, 8 February 2026
As of January 1, 2026, the Supreme Court of the United States has handed down three per curiam opinions during its 2025 term. This term began on October 6, 2025, and will end on October 4, 2026.
Because per curiam decisions are issued from the Court as an institution, these opinions all lack the attribution of authorship or joining votes to specific justices. All justices on the Court at the time the decision was handed down are assumed to have participated and concurred unless otherwise noted.
Chief Justice: John Roberts
Associate Justices: Clarence Thomas, Samuel Alito, Sonia Sotomayor, Elena Kagan, Neil Gorsuch, Brett Kavanaugh, Amy Coney Barrett, Ketanji Brown Jackson
Pitts v. Mississippi
[edit]
607 U.S. ___ (2025)
Decided November 24, 2025.
The Confrontation Clause of the Sixth Amendment requires an individualized finding that a screen is necessary to protect a child from trauma before it can be placed between the child and the defendant during testimony in a criminal trial.
| Full caption: | Terence Clark v. Jeremiah Antoine Sweeney |
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| Citations: | 607 U.S. ___ (2025) |
| Laws applied: | Party Presentation Principle |
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| Full text of the opinion: | official slip opinion · Justia · [ SCOTUS Blog] |
607 U.S. ___ (2025)
Decided November 24, 2025.
The Fourth Circuit erred in granting habeas relief to Sweeney based on a claim of constitutional error that he had never alleged.
Sweeney was convicted of multiple crimes in state court. At trial, a juror unlawfully visited the crime scene. That juror reported the findings to the jury. The judge removed that delinquent juror, but the judge didn’t call a mistrial and Sweeney’s counsel did not voir dire the remaining jurors to assess the effect of the delinquent juror’s actions on them. This failure to voir dire formed the basis of a habeas petition in Federal District Court, which denied relief under Strickland v. Washington. Sweeney only raised one issue in federal court, the ineffective assistance of his counsel at trial. Sweeney appealed. The Fourth Circuit granted relief on the basis of multiple errors committed by judge, jury and attorneys. None of those errors was ever raised, and Clark had no opportunity to respond. Therefore, the Supreme Court held that the Fourth Circuit violated the party presentation principle[1]. See US v. Sineneng-Smith
Doe v. Dynamic Physical Therapy, LLC
[edit]
607 U.S. ___ (2025)
Decided December 8, 2025.
States have no power to create immunity for federal causes of action. Accordingly, the Louisiana Court of Appeal‘s decision holding that a Louisiana state law barred federal claims against health care providers is reversed.
607 U.S. ___ (2026)
Decided January 26, 2026.
Because the Court of Appeals for the Fourth Circuit affirmed the award of a new trial based on reasoning that departed from the strict standards that govern the grant of federal habeas relief to prisoners convicted in state court prescribed by the Antiterrorism and Effective Death Penalty Act of 1996, the Court grants the State’s petition for a writ of certiorari and reverses the judgment below.
Justice Jackson would deny the petition for a writ of certiorari.
