Facts of the Case
David Long was convicted for possession of marijuana found by Michigan police in the passenger compartment and trunk of his car. The police searched the passenger compartment because they suspected Long's vehicle contained weapons potentially dangerous to the officers. After a state appellate court affirmed the conviction, the Michigan Supreme Court reversed. The Michigan Supreme Court held that the search violated the Fourth Amendment and the Michigan Constitution.
Questions
Did the Supreme Court have jurisdiction over state court decisions that rested on "adequate and independent" state grounds?
Conclusions
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The Court, after admitting that it had not developed "a satisfying and consistent approach" regarding lower court references to independent state grounds, held that it had jurisdiction in the case. The Court held that when state court decisions appeared to rest primarily on federal law, it would infer that state courts believed that federal law required them to do so. State courts could expressly state that independent grounds were being used in cases as opposed to constitutional grounds. The Court reasoned that this approach would avoid the rendering of advisory opinions and would decrease the intrusive practice of requiring state courts to clarify decisions to the liking of the Justices. In the case at hand, the Court affirmed the constitutionality of the search and affirmed Long's conviction.
Principles of State Constitutional Interpretation
Federalist Society Review, Volume 23
State constitutionalism—the practice of state courts deciding cases on independent state constitutional grounds—is a vital...
