1. Michigan v. Long (1983)
2. Facts: Long was arrested, and alleged that his search and seizure rights had been violated.
3. Procedural Posture: The Michigan State Supreme Court ruled that the police search did violated the Fourth Amendment and the Michigan Constitution’s own search and seizure laws.
4. Issue: Whether the Supreme Court has jurisdiction to review state court judgments which concern federal issues, and which are not clearly based on an adequate and independent state law grounds.
5. Holding: Yes. If the state court decision does not] indicate clearly and expressly by means of a “plain statement” that it is alternatively based on bona fide separate, adequate, and independent grounds the Supreme Court has appellate jurisdiction to review the state court ruling.
6. Majority Reasoning: O’Connor stated that the Court must assume that there are no adequate grounds when it is not clear from the opinion that there were, and the opinion appears to rest primarily on federal law. It was necessary out of respect for the independence of state courts that the presumption of adequate state grounds go against the states so as to promote clarity, thus avoiding excessive remands and advisory opinions. This promotes uniformity in the states interpretation of federal law.
7. Dissent Reasoning: Stevens stated that it would be better to give the presumption for adequate state grounds to the state, because of historical concerns of judicial restraint. The Supreme Court should not be involved unless there is a reason to vindicate the federal rights of a party. A presumption against independent state grounds would have the Court expounding their understanding
