| Venue: | SCOTUS |
| Facts: | Traffic stop. Police see something that makes them search the driver's compartment: oh-oh, it's marijuana. Long also has 75 additional pounds of the stuff in his trunk, and that gets noticed as well. |
| Posture: | Circuit court denies Long's motion to suppress the evidence, and he gets convicted. MI Ct. App. affirms, saying this was a protective search under Terry and a valid inventory search under South Dakota v. Opperman. MI supremes reverse. Appeal (by the prosecution). |
| Issue: | Two of them:
|
| Holding: | Yes, and yes. MI Supremes are reversed. |
| Rule: | In the absence of a plain statement that the decision below rested on an independent and adequate state ground, SCOTUS has jurisdiction. |
| Reasoning: | First off, we need to determine for ourselves whether the asserted
non-federal ground for the decision independently and adequately
supported the judgment.
There's an important need for uniformity in federal law that goes unmet if we fail to review decisions that rest on federal grounds. We respect state courts, and we don't want to issue advisory opinions, so we don't want to decide issues of state law that go beyond the ionion we review, or require state courts to clarify their decisions. So if we can see that there's a bona fide express adequate independent grounding for the decision, we'll leave it be. It is fundamental that state courts must be left free to interpret their own state constitutions. At the same time, ambiguity and obscurity don't stand as barriers to this court determining the validity of state action under the federal constitution. So by default, we assume there are no non-federal grounds, unless we are explicitly told that there are. And here the court relies almost exclusively on federal case law. Q.E.D. |
| Dicta: | Stevens (dissenting): We're not here to expound the constitution,
we're here to settle disputes. We have the power to correct
wrong judgments, not revise opinions. When we're reviewing
state courts, our primary role is to make sure that persons
seeking to vindicate their federal rights are adequately heard.
Oh, and also allocation of federal resources: we should use restraint here. |