Also known as: independent states · sovereign state
Written by attorneys · grounded in primary & secondary sources — see below
A ground for decision in a state court judgment that rests solely on state law and is adequate to support the outcome without regard to federal law. When a state court decision invokes both state and federal grounds without clearly indicating that the state ground is adequate and independent, the Supreme Court presumes jurisdiction and treats the decision as resting on federal law.
The State of New York sued Peak Trade over sales tracking practices that collected customer data. The state supreme court upheld a ban, citing both a state consumer protection clause and federal search law without stating which ground alone controlled. Because the opinion lacked a clear statement that the judgment rested on independent state law, the Supreme Court presumes jurisdiction to review the federal issue.
A resident creditor obtained a state court judgment against nonresident Neff based on attachment of property in the forum state. The state court treated the states as possessing authority equivalent to that of independent states over persons and property within their borders except as limited by the Constitution. That characterization determined whether the judgment could bind the absent owner.
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Maryland imposed a tax on the Bank of the United States operating within the state. The state defended the levy by arguing that the Constitution was an act of sovereign and independent states that delegated limited powers to the federal government. The Court rejected that view and held that the states lack power to tax an instrument created by federal authority.
A student carried a handgun to school in violation of a federal statute. The state argued that education and crime control remain core powers of independent states under the federal structure. The Court examined whether Congress had exceeded its enumerated powers, underscoring the limits on federal authority over matters traditionally left to state control.
Massachusetts sought to enjoin federal officials from enforcing a spending program that conditioned funds on state compliance. The state asserted its status as an independent sovereign entitled to challenge federal action that invaded reserved powers. The Court held that a state may not sue the federal government as parens patriae to protect its citizens from federal law.
The House of Representatives voted to exclude a duly elected member on grounds of prior misconduct. The member sued, arguing that the states retain independent authority to determine the qualifications of their chosen representatives. The Court held that the House lacked power to add qualifications beyond those stated in the Constitution.
The Supreme Court may review the decision unless the state court clearly and expressly states that its judgment rests on state-law grounds independent of federal law. Ambiguous or mixed references trigger a presumption of jurisdiction.
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The Supreme Court presumes that the decision rests on federal law and exercises appellate jurisdiction. The state court cannot later supply the missing clarity after the fact.
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No. Partial reliance on state law does not by itself defeat jurisdiction. The controlling question is whether the state court itself clearly and expressly identified an independent state ground.
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…on its merits. The counsel for Maryland have argued that the Constitution should be considered as the act of sovereign and independent States and that the powers of the General Government are delegated by the States and must be exercised in subordination to them. That proposition is difficult to sustain. The Constitution was…