Michigan v. Long
Michigan v. Long is a significant Supreme Court case that addresses the interpretation of "independent and adequate state grounds" in relation to state court decisions. Originating from a Michigan Supreme Court ruling concerning automobile searches, the case highlights the complexities surrounding how state court interpretations may intersect with federal law. In a 6-3 decision, the Court established a presumption that state court decisions are based on federal law, unless explicitly indicated otherwise by the state court itself. Justice Sandra Day O'Connor articulated that this presumption holds unless a state court clearly signifies that its ruling is grounded solely in state law. The decision has implications for how state and federal jurisdictions interact, particularly in legal matters involving constitutional rights. This ruling reflects ongoing tensions in the judicial system regarding the autonomy of state courts versus the overarching authority of federal law. The case draws significant attention from legal scholars and practitioners who are interested in the dynamics of state-federal relationships in the U.S. legal system.
Michigan v. Long
Date: July 6, 1983
Citation: 463 U.S. 1062
Issue: Independent and adequate state grounds
Significance: The Supreme Court declared that it would assume that state courts relied on federal law unless the courts clearly demonstrated otherwise.
By a 6-3 vote, the Supreme Court attempted to unravel the perplexing question of how to interpret the “independent and adequate state grounds” issue. The case sprang from a Michigan supreme court decision about automobile searches. The ambiguity concerning just what constitutional provisions were involved in the lower court’s decision led the Court to declare that it would regard state decisions as being based on federal law in most cases. In her opinion for the Court, Justice Sandra Day O’Connor stated that federal law was assumed to be the guiding model unless the state court clearly indicated that “federal cases were only being used for guidance” and the decision rested on “adequate and independent” state grounds. Justice Harry A. Blackmun concurred. Justices William J. Brennan, Jr., Thurgood Marshall, and John Paul Stevens dissented.
