No. 25-52

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

Lower Court: Fourth Circuit
Docketed: 2025-07-15
Status: Judgment Issued
Type: Paid
Response RequestedResponse WaivedRelisted (4) Experienced Counsel
Tags: AEDPA exhaustion-requirement fourth-circuit habeas-corpus merits-standard party-presentation
Latest Conference: 2025-11-21 (distributed 4 times)
Question Presented (from Petition)

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 (2) 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:

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

2. 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?

3. 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?

Question Presented (AI Summary)

Did the Fourth Circuit violate the party presentation principle, improperly circumvent AEDPA's exhaustion requirement, and flout the AEDPA merits standard in granting federal habeas relief?

Docket Entries

2025-12-29
Judgment Issued.
2025-11-24
Petition GRANTED. Judgment REVERSED and case REMANDED for further proceedings consistent with the opinion of the Court. Opinion per curiam. (Detached Opinion)
2025-11-17
DISTRIBUTED for Conference of 11/21/2025.
2025-11-10
DISTRIBUTED for Conference of 11/14/2025.
2025-10-22
DISTRIBUTED for Conference of 11/7/2025.
2025-10-21
Reply of petitioners Terence Clark, Dir., et al. filed. (Distributed)
2025-10-21
Reply of Terence Clark, Dir., PGC DOC, et al. submitted.
2025-10-02
Brief of Jeremiah Sweeney in opposition submitted.
2025-10-02
Brief of respondent Jeremiah Sweeney in opposition filed.
2025-08-18
Motion to extend the time to file a response is granted and the time is extended to and including October 2, 2025.
2025-08-15
Motion to extend the time to file a response from September 2, 2025 to October 2, 2025, submitted to The Clerk.
2025-08-15
Motion of Jeremiah Sweeney for an extension of time submitted.
2025-07-31
Response Requested. (Due September 2, 2025)
2025-07-30
DISTRIBUTED for Conference of 9/29/2025.
2025-07-27
Waiver of Jeremiah Sweeney of right to respond submitted.
2025-07-25
Waiver of right of respondent Jeremiah Sweeney to respond filed.
2025-07-07

Attorneys

Jeremiah Sweeney
Michael James ConfusioneHegge & Confusione, Respondent
Jo-Ann Tamila SagarHogan Lovells US LLP, Respondent
Terence Clark, Dir., PGC DOC, et al.
Andrew John DiMiceliMaryland Office of the Attorney General, Petitioner