Also known as: independent state grounds · adequate and independent state ground
Written by attorneys · grounded in primary & secondary sources — see below
A state-law ground of decision that fully supports the judgment and does not depend on federal law. Such a ground bars Supreme Court review of the state judgment. When a state court opinion leaves unclear whether its holding rests on an adequate and independent state ground, the Supreme Court presumes that federal law supplies the basis for decision and that jurisdiction exists unless the state court clearly and expressly states that its judgment rests on independent state-law grounds.
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ChatterWave challenged a Redmont Privacy Commission order in state court. The state supreme court upheld the order after discussing both the state constitution's speech and privacy clauses and federal free speech protections, stating only that its holding was consistent with federal law. Because the opinion never clearly announced that state law alone controlled, the Supreme Court presumes jurisdiction over ChatterWave's certiorari petition.
Ake moved for a new trial in Oklahoma state court after his capital conviction and requested psychiatric assistance. The state court denied relief and added that the request was waived because it was not renewed in the new-trial motion. The Supreme Court reviewed the federal constitutional claim because the state waiver holding did not clearly rest on an independent state ground.
A state prisoner challenged his conviction in state court on both state evidentiary rules and federal due process grounds. The state supreme court affirmed without clearly and expressly stating that its judgment rested on the state rules alone. The Supreme Court presumed jurisdiction to review the federal claim under the controlling authority.
Clark was convicted of murder in Arizona after the trial court excluded evidence of his mental illness offered to negate mens rea. The state appellate court affirmed on both state evidentiary rules and federal due process grounds without clearly stating that the state rule alone supported the judgment. The Supreme Court presumed jurisdiction to review the federal claim.
Stop the Beach Renourishment challenged a Florida beach restoration project in state court. The Florida Supreme Court upheld the project after analyzing both state property law and federal takings doctrine without expressly declaring that the state ground was independent. The Supreme Court presumed jurisdiction over the federal claim.
Carney was convicted in California after police searched his motor home without a warrant. The state supreme court suppressed the evidence under both state and federal search-and-seizure rules without clearly stating that the state ground alone supported the result. The Supreme Court presumed jurisdiction to review the federal Fourth Amendment issue.
The Supreme Court presumes jurisdiction whenever the state court opinion leaves unclear whether its judgment rests on an adequate and independent state ground. The presumption applies unless the state court clearly and expressly states that its decision rests on state-law grounds independent of federal law.
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…determining the primacy of state law, see, e. g. , Erie R. Co. v. Tompkins , 304 U. S. 64 (1938), the doctrine of adequate and independent state grounds, see, e. g. , Murdock v. Memphis , 20 Wall. 590 (1875); Michigan v. Long , 463 U. S. 1032 (1983), the whole jurisprudence of pre-emption, see, e. g. , Rice v. Santa Fe Elevator Corp. ,…
…articulated in Terry and other decisions of this Court. We also examine Long's argument that the decision below rests upon an adequate and independent state ground, and we decide in favor of our jurisdiction. I Deputies Howell and Lewis were on patrol in a rural area one evening when, shortly after midnight, they observed a car traveling…
…Michigan v. Long , 463 U.S. 1032, 1042 (1983) (“[I]t is not clear from the opinion itself that the state court relied upon an adequate and independent state ground
…for this proposition. The State argued in its brief to this Court that the court’s holding on this issue therefore rested on an
…petitioner who seeks federal habeas exhaust state remedies before resorting to the federal court? (4) In what instances will an
No. A statement that a holding is consistent with federal law does not constitute a clear and express declaration that the judgment rests on independent state grounds. The Supreme Court therefore presumes jurisdiction.
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The state court must clearly and expressly state that its judgment rests on state-law grounds independent of federal law. Without that explicit statement, the Supreme Court presumes jurisdiction even if the opinion emphasizes state constitutional provisions.
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No. The presence of state constitutional analysis does not automatically defeat jurisdiction. Jurisdiction is barred only when the opinion clearly and expressly rests the judgment on an adequate and independent state ground.
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