Clark v. Sweeney
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Clark v. Sweeney and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Clark v. Sweeney.
The Supreme Court reversed the Fourth Circuit's decision to order a new trial for Jeremiah Sweeney, who was convicted of second-degree murder. The Fourth Circuit had relied on a claim not raised by Sweeney, which violated the principle of party presentation. The case involved issues related to a juror's independent investigation and subsequent dismissal during deliberations.
Holding
The single most important “bottom line” of what the Court decided in Clark v. Sweeney.
The Court held that the Fourth Circuit erred by considering a claim that Sweeney never asserted.
Constitutional Concepts
These are the Constitution-related themes that appear in Clark v. Sweeney. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Clark v. Sweeney
The Court's decision focused on the procedural error of the Fourth Circuit in considering a claim not raised by the parties, which implicates procedural due process principles.
Syllabus excerpt (verbatim)Because the Court of Appeals departed dramatically from the principle of party presentation, we reverse.
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Why Right to Jury Trial is relevant to Clark v. Sweeney
The issue of Juror 4's independent investigation and subsequent dismissal touches on the integrity of the jury trial process.
Syllabus excerpt (verbatim)The parties conferred and eventually agreed that rather than declare a mistrial, the court would dismiss Juror 4 and deliberations would proceed with 11.
Key Quotes
Short excerpts from the syllabus in Clark v. Sweeney that support the summary and concepts above.
The Fourth Circuit reversed and ordered a new trial, relying on a claim that Sweeney never asserted.
Juror 4’s curiosity got the best of him, and he decided to check out the crime scene for himself.
The parties conferred and eventually agreed that rather than declare a mistrial, the court would dismiss Juror 4.
