Adequate and independent state ground
Encyclopedia
The adequate and independent state ground doctrine is a doctrine
of United States law governing the power of the U.S. Supreme Court to review judgments entered by state courts.
This general rule is simple to apply in cases clearly involving only one body of law. If that law is federal, then the U.S. Supreme Court has jurisdiction to review the state court judgment; if it is state law, then it does not. However, because litigants can (and often do) raise federal claims in state courts, many cases are not so simple, and this general rule breaks down. Indeed, state courts often dismiss cases raising federal claims because they fail to comply with state-law procedures, and in some cases federal and state law are not clearly distinct; instead they are intertwined. The adequate and independent state ground doctrine provides certain exceptions to this general rule and guides the U.S. Supreme Court’s exercise of jurisdiction over these complex cases.
, 463 U.S. 1032, 1038 (1983) (“It is, of course, incumbent upon this Court to ascertain for itself whether the asserted non-federal ground independently and adequately supports the judgment.” (internal quotation marks omitted)); Fox Film Corp. v. Muller
, 296 U.S. 207, 210 (1935) (“[W]here the judgment of a state court rests upon two grounds, one of which is federal and the other non-federal in character, our jurisdiction fails if the non-federal ground is independent of the federal ground and adequate to support the judgment.”); Murdock v. City of Memphis
, ("[W]hether there exist other matters in the record actually decided by the State court which are sufficient to maintain the judgment of that court, notwithstanding the error in deciding the Federal question. In [that case] the court would not be justified in reversing the judgment of the State court.").
The “adequacy” prong primarily focuses on state court dismissals of federal claims on state procedural grounds, as procedural requirements are by definition logically antecedent. Antecedent state-law grounds (i.e., state rules of procedure) are adequate to support a judgment unless they (1) are arbitrary, unforeseen, or otherwise deprive the litigant of a reasonable opportunity to be heard, see, e.g., Staub v. City of Baxley, 355 U.S. 313, 319-20 (1958), or (2) impose an undue burden on the ability of litigants to protect their federal rights, see, e.g., Felder v. Casey, 487 U.S. 131, 138 (1988).
The “independence” prong focuses on decisions where the state and federal rules are not clearly distinct. If it is not "apparent from the four corners” of the opinion that the judgment rests on an independent state law rule, then, unless it is “necessary or desirable” to obtain clarification from the state court itself, the Supreme Court will presume that the decision rested in part on federal law, thereby rendering it reviewable. Michigan v. Long
, 463 U.S. 1032, 1040 & n.6. Furthermore, when federal law limits the states’ ability to change the definition of state-created legal interests, the Supreme Court has jurisdiction to review the state court’s characterization of the law both before and after the change. For example, the U.S. Supreme Court routinely reviews state court determinations of state property law to determine whether a litigant has been deprived of “property” within the meaning of the Due Process clause.
Legal doctrine
A legal doctrine is a framework, set of rules, procedural steps, or test, often established through precedent in the common law, through which judgments can be determined in a given legal case. A doctrine comes about when a judge makes a ruling where a process is outlined and applied, and allows...
of United States law governing the power of the U.S. Supreme Court to review judgments entered by state courts.
Introduction
It is part of the basic framework of the American legal system that the U.S. Supreme Court is the ultimate arbiter of questions of federal law but the state courts are the ultimate arbiters of the laws of each state. See, e.g., Hortonville Joint School District No. 1. v. Hortonville Education Ass’n, 426 U.S. 482, 488 (1976) (“We are, of course, bound to accept the interpretation of [State] law by the highest court of the State.”). Thus, generally speaking, the U.S. Supreme Court has the authority (“jurisdiction”) to review state court determinations of federal law, but lacks jurisdiction to review state court determinations of state law. See 28 U.S.C. § 1257.This general rule is simple to apply in cases clearly involving only one body of law. If that law is federal, then the U.S. Supreme Court has jurisdiction to review the state court judgment; if it is state law, then it does not. However, because litigants can (and often do) raise federal claims in state courts, many cases are not so simple, and this general rule breaks down. Indeed, state courts often dismiss cases raising federal claims because they fail to comply with state-law procedures, and in some cases federal and state law are not clearly distinct; instead they are intertwined. The adequate and independent state ground doctrine provides certain exceptions to this general rule and guides the U.S. Supreme Court’s exercise of jurisdiction over these complex cases.
The Doctrine
The adequate and independent state ground doctrine states that when a litigant petitions the U.S. Supreme Court to review the judgment of a state court which rests upon both federal and non-federal (state) law, the U.S. Supreme Court does not have jurisdiction over the case if the state ground is (1) “adequate” to support the judgment, and (2) “independent” of federal law. See Michigan v. LongMichigan v. Long
Michigan v. Long, 463 U.S. 1032 , was a decision by the United States Supreme Court that extended Terry v. Ohio, 392 U.S. 1 to allow searches of car compartments during a stop with reasonable suspicion. The case also clarified and narrowed the extent of adequate and independent state ground,...
, 463 U.S. 1032, 1038 (1983) (“It is, of course, incumbent upon this Court to ascertain for itself whether the asserted non-federal ground independently and adequately supports the judgment.” (internal quotation marks omitted)); Fox Film Corp. v. Muller
Fox Film Corp. v. Muller
Fox Film Corp. v. Muller, 296 U.S. 207 , was a case in which the Supreme Court of the United States held that it cannot exert certiorari jurisdiction over a case in which there is an adequate and independent state law ground for the state court's final judgment.-Facts:Plaintiff Fox Film Corporation...
, 296 U.S. 207, 210 (1935) (“[W]here the judgment of a state court rests upon two grounds, one of which is federal and the other non-federal in character, our jurisdiction fails if the non-federal ground is independent of the federal ground and adequate to support the judgment.”); Murdock v. City of Memphis
Murdock v. City of Memphis
Murdock v. Memphis, 87 U.S. 590 , is a case decided by the United States Supreme Court.William Tod Otto argued the case on behalf of the City of Memphis...
, ("[W]hether there exist other matters in the record actually decided by the State court which are sufficient to maintain the judgment of that court, notwithstanding the error in deciding the Federal question. In [that case] the court would not be justified in reversing the judgment of the State court.").
The “adequacy” prong primarily focuses on state court dismissals of federal claims on state procedural grounds, as procedural requirements are by definition logically antecedent. Antecedent state-law grounds (i.e., state rules of procedure) are adequate to support a judgment unless they (1) are arbitrary, unforeseen, or otherwise deprive the litigant of a reasonable opportunity to be heard, see, e.g., Staub v. City of Baxley, 355 U.S. 313, 319-20 (1958), or (2) impose an undue burden on the ability of litigants to protect their federal rights, see, e.g., Felder v. Casey, 487 U.S. 131, 138 (1988).
The “independence” prong focuses on decisions where the state and federal rules are not clearly distinct. If it is not "apparent from the four corners” of the opinion that the judgment rests on an independent state law rule, then, unless it is “necessary or desirable” to obtain clarification from the state court itself, the Supreme Court will presume that the decision rested in part on federal law, thereby rendering it reviewable. Michigan v. Long
Michigan v. Long
Michigan v. Long, 463 U.S. 1032 , was a decision by the United States Supreme Court that extended Terry v. Ohio, 392 U.S. 1 to allow searches of car compartments during a stop with reasonable suspicion. The case also clarified and narrowed the extent of adequate and independent state ground,...
, 463 U.S. 1032, 1040 & n.6. Furthermore, when federal law limits the states’ ability to change the definition of state-created legal interests, the Supreme Court has jurisdiction to review the state court’s characterization of the law both before and after the change. For example, the U.S. Supreme Court routinely reviews state court determinations of state property law to determine whether a litigant has been deprived of “property” within the meaning of the Due Process clause.
Sample cases
- Murdock v. Memphis, 87 U.S. 590 (1875)
- Seneca Nation of Indians v. ChristySeneca Nation of Indians v. ChristySeneca Nation of Indians v. Christy, 162 U.S. 283 , was the first litigation of aboriginal title in the United States by a tribal plaintiff in the Supreme Court of the United States since Cherokee Nation v. Georgia , and the first such litigation by an indigenous plaintiff since Fellows v....
, 162 U.S. 283 (1896) - Fox Film Corp. v. MullerFox Film Corp. v. MullerFox Film Corp. v. Muller, 296 U.S. 207 , was a case in which the Supreme Court of the United States held that it cannot exert certiorari jurisdiction over a case in which there is an adequate and independent state law ground for the state court's final judgment.-Facts:Plaintiff Fox Film Corporation...
, 296 U.S. 207 (1935) - Michigan v. LongMichigan v. LongMichigan v. Long, 463 U.S. 1032 , was a decision by the United States Supreme Court that extended Terry v. Ohio, 392 U.S. 1 to allow searches of car compartments during a stop with reasonable suspicion. The case also clarified and narrowed the extent of adequate and independent state ground,...
, 463 U.S. 1032 (1983)