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The Court unanimously held that restitution imposed under the Mandatory Victims Restitution Act is a form of criminal punishment, meaning it cannot be applied to conduct that occurred before the statute was enacted without violating the Ex Post Facto Clause. Although Ellingburg’s offense predated the MVRA, he was sentenced under it and ordered to pay restitution. The Eighth Circuit had treated MVRA restitution as a civil, nonpunitive measure, but the Supreme Court rejected that view. Looking to the statute’s text, structure, and placement within the criminal code, the Court emphasized that restitution is imposed only on convicted defendants, at sentencing, alongside imprisonment and fines, and through procedures governing criminal penalties. Prior precedents likewise treated MVRA restitution as punitive. While restitution also serves compensatory aims, victims cannot control or negotiate it as they could in a civil action, underscoring its criminal nature. The Court therefore reversed and remanded.

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1. The Court has jurisdiction because §2244(b)(3)(E) does not bar this Court’s review of a federal prisoner’s request to file a second or successive §2255 motion. Pp. 5–19. (a) Section 2244(b)(3)(E) provides that the denial of authorization “to file a second or successive application” shall not be the subject of a certiorari petition. That provision does not apply to federal prisoners. It is housed within §2244, which imposes several strict requirements that apply only to state prisoners.

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State Courts may not grant releif from FEDERAL causes of action by reference to state statute.

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an appeal of a VOID judgement under federal rule 60 is still subject to the statutory text's "within a reasonable time" limit.

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Supreme Court refuses to assume that Congress intended to disregard Blockburger and allow someone to be convicted of two crimes in the same statute. Congress' clear intent here was to create two potential sentencing schemes, not allow someone to be convicted twice.

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Supreme Court Upholds Montana's Community Caretaker exception to the 4th amendment prohibition on warrantless searches.

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In Clark v. Sweeney, the Supreme Court reversed a Fourth Circuit decision that had granted habeas relief on a theory the petitioner never raised. A Maryland jury convicted Jeremiah Sweeney of second-degree murder, and his convictions were affirmed on appeal. In postconviction proceedings, Sweeney argued that trial counsel was ineffective for failing to request voir dire of the full jury after a juror conducted an unauthorized visit to the crime scene. State courts rejected that claim, and the federal district court likewise denied habeas relief, concluding that the state court’s application of Strickland was not objectively unreasonable.

The Fourth Circuit reversed, not on the ineffective-assistance claim Sweeney actually asserted, but on a new theory that a combination of failures by the juror, the judge, and counsel violated Sweeney’s confrontation and jury rights. The panel ordered a new trial despite the State never having the opportunity to address that theory. A dissent criticized the majority for disregarding fundamental principles of party presentation.

The Supreme Court held that the Fourth Circuit had “departed so drastically from the principle of party presentation as to constitute an abuse of discretion.” In the Court’s view, federal courts may not grant relief on claims the petitioner did not present and that the State had no chance to contest. The case is remanded for the Fourth Circuit to evaluate only the ineffective-assistance claim Sweeney actually pursued, under AEDPA’s deferential standards governing federal review of state adjudications of Strickland claims.

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The United States Supreme Court reversed a decision of the Mississippi Supreme Court upholding the use of a physical screen that prevented a four-year-old child witness from seeing the defendant during trial. Mississippi law mandates the use of such screens for child witnesses in abuse cases. Relying on that statute, the trial court permitted the screen without taking evidence or making any case-specific finding that the arrangement was necessary to protect the witness.

On review, the Mississippi Supreme Court concluded that the statute, combined with state constitutional victims’ rights provisions, distinguished the case from Coy v. Iowa and Maryland v. Craig, which require individualized findings before limiting face-to-face confrontation. The dissent argued that those precedents squarely controlled and that the trial court failed to comply with their requirements.

The U.S. Supreme Court held that Coy and Craig govern: a deviation from face-to-face confrontation is permissible only after the trial court hears evidence and finds that testifying in the defendant’s presence would cause trauma that impairs the child’s ability to communicate. The mandatory nature of Mississippi’s statute could not substitute for those constitutional findings, and the trial court’s reliance on the statute alone was insufficient.

The Court remanded for consideration of whether the Confrontation Clause violation was harmless beyond a reasonable doubt.