Terence Clark, Director, Prince George's County Department of Corrections, et al. v. Jeremiah Antoine Sweeney

The Antiterrorism and Effective Death Penalty Act (AEDPA) prohibits federal courts from granting habeas relief on any claim alleged by a habeas petitioner who challenges a state-court conviction unless (1) the state courts have first been afforded a full and fair opportunity to adjudicate the claim; and

1. the state courts’ rejection of the claim is contrary to, or an unreasonable application of, federal law as determined by the holdings of this Court. In this case, a divided panel of the United States Court of Appeals for the Fourth Circuit declared that a series of largely unexhausted and unraised errors it perceived in respondent Jeremiah Antoine Sweeney’s trial “t[ook] this case beyond . . . traditional habeas review” and required relief. App. 22a. The questions presented, which warrant summary reversal, are as follows:

2. Did the Fourth Circuit violate the partypresentation principle by granting federal habeas relief based on putative errors in the state trial proceedings that Mr. Sweeney never alleged?

3. Did the Fourth Circuit improperly circumvent AEDPA’s exhaustion requirement by applying a “special circumstances” exception derived from Frisbie v. Collins, 342 U.S. 519 (1952), and Granberry v. Greer, 481 U.S. 129 (1987), that AEDPA eliminated and that has no applicability beyond the unique circumstances of those cases, as other courts of appeals have concluded?

4. Did the Fourth Circuit flout the AEDPA merits standard by granting federal habeas relief in the absence of clearly established federal law as determined by the holdings of this Court?