Federal Court's Authority to Review STATE Court Determinations

Question 1

Supreme Court review of STATE Court Determinations is LIMITED to:

Answer 1

1. Questions of FEDERAL LAW
2. State Ct judgments IMPLICATING FEDERAL CONSITUTIONAL VIOLATIONS [including review of criminal cases / cases in which the State is a party]

Question 2

Federal Courts have NO jx to review:

Answer 2

State Court determinations where the basis is on ADEQUATE and INDEPENDENT State grounds. [Next Slide]

BUT “plain statement” requirement expands Federal Court review power

Question 3

Advantages of Doctrine of ADEQUATE and INDEPENDENT State grounds

Answer 3

• Prevents improvident use of the Supreme Court resources om State high court decision alreadt sufficiently supported under state law
• Comity between soverign states and Federal Courts
• Ensures that US Supreme Court does not overstep it’s jx bounds – [Art. 3 Sec 2, forbids the Ct from issuing advisiory opinions that do not affect the outcome of a case - If the Ct were to review a state high ct decision supported by Adequate + Independent State Grounds –> its opinion would be purely academic]

Question 4

State Procedural grounds are usually ADEQUATE IF they – Doctrine of ADEQUATE and INDEPENDENT State grounds

Answer 4

1. Do NOT deny due process / violate any other constitutional provision
2. Advance a legitimate state interest; AND
3. Are applied consistently

Question 5

State Procedural grounds are usually INDEPENDENT IF they are – Doctrine of ADEQUATE and INDEPENDENT State grounds

Answer 5

NOT based on Federal law OR State court’s understanidng/interpretation of Federal law

• I.e. State Ct may interpret it’s state constitution in a manner that is coextensive with the federal constitution and this base this decision on it’s interpretation of federal constitutional law –> NOT Independent

Question 6

NOT Clear if State Court decision is based on ADEQUATE and INDEPENDENT State grounds

Answer 6

Michigan v. Long Plain Statement
- There is a presumption that NO Adequate and Independent State grounds IF –>
- there is **NO plain statement in its judgment/opinion that
- indicates clearly and expressly** that [the decision] is alternatively based on a bona fide seperate, adequate and independent grounds.