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 . Thus, generally speaking, the U.S. Supreme Court has the authority to review state court determinations of federal law, but lacks jurisdiction to review state court determinations of state law. See . 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 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.
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 law, the U.S. Supreme Court does not have jurisdiction over the case if the state ground is “adequate” to support the judgment, and “independent” of federal law. See Michigan v. Long, 463 U.S. 1032, 1038 ; Fox Film Corp. v. Muller, 296 U.S. 207, 210 ; Murdock v. City of Memphis,. 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 are adequate to support a judgment unless they 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, or 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. 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.
