Independent and adequate state grounds doctrine Summary

In Michigan v. Long[case]Michigan v. Long[Michigan v. Long] (1983), the Supreme Court ruled that it can decide whether an asserted state ground independently and adequately supports the state court’s judgment. If it does not, the Court may review the state court’s decision. The Court ruled that it will assume independent state grounds do not exist when it is not clear from the opinion that the state court relied upon adequate and independent state grounds in Pennsylvania v. Labron[case]Pennsylvania v. Labron[Pennsylvania v. Labron] (1996). In Ohio v. Robinette[case]Ohio v. Robinette[Ohio v. Robinette] (1996), the Court determined that independent grounds could be considered lacking when state and federal grounds were so intertwined as not to be independent or when it appeared that the state court rested its decision primarily on federal law.

State courts may choose to rely on federal cases for precedents but must make clear that they are citing federal cases for guidance only and that they are not requiring the same result in the case. In Lambrix v. Singletary[case]Lambrix v. Singletary[Lambrix v. Singletary] (1997), the Court ruled that state courts must indicate clearly and expressly that their decisions are based on bona fide separate, adequate, and independent state grounds if they want to avoid a review of their decisions by the Court.

Constitutional interpretation

State constitutions

State courts

States’ rights and state sovereignty