Clark v. Sweeney

Issue: (1) Whether the Fourth Circuit violated the party-presentation principle by granting federal habeas relief based on putative errors in the state trial proceedings that the respondent never alleged; (2) whether the Fourth Circuit improperly circumvented the Antiterrorism and Effective Death Penalty Act's exhaustion requirement by applying a “special circumstances” exception derived from Frisbie v. Collins and Granberry v. Greer; and (3) whether the Fourth Circuit flouted the AEDPA merits standard by granting federal habeas relief in the absence of clearly established federal law as determined by the holdings of the Supreme Court.