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The adequate and independent state ground doctrine is a doctrine of United States law governing the power of the U.S. Supreme Court to review judgments entered by state courts.
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 (1976) (“We are, of course, bound to accept the interpretation of [State] law by the highest court of the State.”). Thus, generally speaking, the U.S. Supreme Court has the authority (“jurisdiction”) to review state court determinations of federal law, but lacks jurisdiction to review state court determinations of state law. See 28 U.S.C. § 1257.
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 (and often do) 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.
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 (state) law, the U.S. Supreme Court does not have jurisdiction over the case if the state ground is (1) “adequate” to support the judgment, and (2) “independent” of federal law. See Michigan v. Long , 463 U.S. 1032, 1038 (1983) (“It is, of course, incumbent upon this Court to ascertain for itself whether the asserted non-federal ground independently and adequately supports the judgment.” (internal quotation marks omitted)); Fox Film Corp. v. Muller , 296 U.S. 207, 210 (1935) (“[W]here the judgment of a state court rests upon two grounds, one of which is federal and the other non-federal in character, our jurisdiction fails if the non-federal ground is independent of the federal ground and adequate to support the judgment.”); Murdock v. City of Memphis , ("[W]hether there exist other matters in the record actually decided by the State court which are sufficient to maintain the judgment of that court, notwithstanding the error in deciding the Federal question. In [that case] the court would not be justified in reversing the judgment of the State court.").
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 (i.e., state rules of procedure) are adequate to support a judgment unless they (1) 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 (1958), or (2) 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 (1988).
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.
A precedent is a principle or rule established in a previous legal case that is either binding on or persuasive for a court or other tribunal when deciding subsequent cases with similar issues or facts. Common-law legal systems place great value on deciding cases according to consistent principled rules, so that similar facts will yield similar and predictable outcomes, and observance of precedent is the mechanism by which that goal is attained. The principle by which judges are bound to precedents is known as stare decisis. Common-law precedent is a third kind of law, on equal footing with statutory law and subordinate legislation.
A lawsuit is a proceeding by a party or parties against another in the civil court of law. The archaic term "suit in law" is found in only a small number of laws still in effect today. The term "lawsuit" is used in reference to a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint. If the plaintiff is successful, judgment is in the plaintiff's favor, and a variety of court orders may be issued to enforce a right, award damages, or impose a temporary or permanent injunction to prevent an act or compel an act. A declaratory judgment may be issued to prevent future legal disputes.
Michigan v. Long, 463 U.S. 1032 (1983), was a decision by the United States Supreme Court that extended Terry v. Ohio, 392 U.S. 1 (1968) to allow searches of car compartments during a stop with reasonable suspicion. The case also clarified and narrowed the extent of adequate and independent state ground, allowing U.S. Supreme Court review of state supreme court decisions unless they explicitly appealed to state laws.
Justiciability concerns the limits upon legal issues over which a court can exercise its judicial authority. It includes, but is not limited to, the legal concept of standing, which is used to determine if the party bringing the suit is a party appropriate to establishing whether an actual adversarial issue exists. Essentially, justiciability in American law seeks to address whether a court possesses the ability to provide adequate resolution of the dispute; where a court believes that it cannot offer such a final determination, the matter is not justiciable.
An abstention doctrine is any of several doctrines that a United States court may apply to refuse to hear a case if hearing the case would potentially intrude upon the powers of another court. Such doctrines are usually invoked where lawsuits involving the same issues are brought in two different court systems at the same time.
Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), is a landmark decision by the Supreme Court of the United States in which the Court held that federal courts did not have the judicial power to create general federal common law when hearing state law claims under diversity jurisdiction. In reaching this holding, the Court overturned almost a century of federal civil procedure case law, and established the foundation of what remains the modern law of diversity jurisdiction as it applies to United States federal courts.
Forum non conveniens (FNC) is a mostly common law legal doctrine whereby a court "acknowledges that another forum or court is more appropriate and sends the case to such a forum. A change of venue, where another venue is more appropriate to adjudicate a matter, such as the jurisdiction within which an accident occurred and where all the witnesses reside."
The Erie doctrine is a fundamental legal doctrine of civil procedure in the United States which mandates that a federal court called upon to resolve a dispute not directly implicating a federal question must apply state substantive law.
The Rooker–Feldman doctrine is a doctrine of civil procedure enunciated by the United States Supreme Court in two cases, Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983). The doctrine holds that lower United States federal courts—i.e., federal courts other than the Supreme Court—should not sit in direct review of state court decisions unless Congress has specifically authorized such relief. In short, federal courts below the Supreme Court must not become a court of appeals for state court decisions. The state court plaintiff has to find a state court remedy, or obtain relief from the U.S. Supreme Court.
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), was a case decided by the United States Supreme Court in which the Court enunciated a rule of civil procedure known as the Rooker-Feldman doctrine. The doctrine holds that lower United States federal courts may not sit in direct review of state court decisions.
Swift v. Tyson, 41 U.S. 1 (1842), was a case brought in diversity in the Circuit Court for the Southern District of New York on a bill of exchange accepted in New York in which the Supreme Court of the United States determined that United States federal courts that heard cases brought under their diversity jurisdiction under the Judiciary Act of 1789 must apply statutory state laws when the state legislatures in question had spoken on the issue but did not have to apply the state's common law if states legislatures had not spoken on the issue.
Fox Film Corp. v. Muller, 296 U.S. 207 (1935), was a case in which the Supreme Court of the United States held that it cannot exert certiorari jurisdiction over a case in which there is an adequate and independent state law ground for the state court's final judgment.
In law, intervention is a procedure to allow a nonparty, called intervenor to join ongoing litigation, either as a matter of right or at the discretion of the court, without the permission of the original litigants. The basic rationale for intervention is that a judgment in a particular case may affect the rights of nonparties, who ideally should have the right to be heard.
Murdock v. City of Memphis, 87 U.S. 590 (1875), is a case decided by the United States Supreme Court.
In Constitutional law, the Last Resort Rule is a largely prudential rule which gives a federal court the power to avoid a constitutional issue in some circumstances. This rule dictates that, even if all other jurisdictional and justiciability obstacles are surmounted, federal courts still must avoid a constitutional issue if there is any other ground upon which to render a final judgment. The last resort rule can function as a distinct barrier to Constitutional avoidance. It is articulated by Justice Brandeis in Ashwander v. Tennessee Valley Authority.
Ashwander v. Tennessee Valley Authority, 297 U.S. 288 (1936), was a United States Supreme Court case that provided the first elaboration of the doctrine of "Constitutional avoidance".
In United States constitutional law, the doctrine of constitutional avoidance dictates that a federal court should refuse to rule on a constitutional issue if the case can be resolved on a nonconstitutional basis. When a federal court is faced with a choice of ruling on a statutory, regulatory or constitutional basis, the Supreme Court has instructed the lower court to decide the federal constitutional issue only as a last resort: "The Court will not pass upon a constitutional question although properly presented by the record, if there is also present some other ground upon which the case may be disposed of." Ashwander v. Tennessee Valley Auth., 297 U.S. 288, 347 (1936).
Beard v. Kindler, 558 U.S. 53 (2009), is a United States Supreme Court case that deals with the federal review of state laws, known as the adequate and independent state ground doctrine.
In law, an appeal is the process in which cases are reviewed, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of clarifying and interpreting law. Although appellate courts have existed for thousands of years, common law countries did not incorporate an affirmative right to appeal into their jurisprudence until the 19th century.
Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.