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Constitutional Law • Supreme Court Review
CONLAW#012
Legal Definition
The Supreme Court will decline to review a state court decisions where there are adequate and independent state grounds for the decision. Where state court decision rests on two grounds (one state and one federal), and the Supreme Court's reversal of the federal law ground will not change the result, the Court will not hear the case. However, where the state court has not expressly stated that the result rests on state law, the court may hear it.
Plain English Explanation
The Supreme Court usually doesn't look at cases from state courts if those cases were decided based on state laws. If a state court messes up something about federal law, then the Supreme Court might step in to correct it. But, if fixing the federal law issue won't change the final decision of the case, the Supreme Court won't bother with it. If it's not clear whether the state court used state or federal law to decide a case, the Supreme Court might decide to take a look at it.
Hypothetical
Hypo 1: Bob files a lawsuit in Hypofornia state court claiming that Sam's new business violates both Hypofornia business regulations and a federal trade law. The Hypofornia court decides in favor of Sam based strictly on Hypofornia's state laws, without addressing the federal trade law. Bob wants to appeal to the Supreme Court. Result: The Supreme Court is unlikely to review the case because the decision was based on state law, not on a misunderstanding or misapplication of federal law.
Hypo 2: Sam sues Bob in New Hypoland's state court for breaching a contract that involves both state and federal environmental regulations. The state court rules in Sam's favor, citing federal environmental law errors made by Bob. Bob appeals to the Supreme Court, arguing the state court misinterpreted federal law. Result: The Supreme Court decides to review the case because it involves a state court's potential mistake in applying federal law, which falls within the Supreme Court's review scope.
Hypo 3: In Hypofornia, Bob sues a local newspaper owned by Sam for defamation, a case typically governed by state law. However, Bob argues that the case involves First Amendment rights, a federal issue. The state court decides based on Hypofornia's defamation laws without addressing the First Amendment claim. Bob appeals to the Supreme Court. Result: The Supreme Court may choose to hear the case since it involves the potential misapplication of federal constitutional law by the state court.
Hypo 4: Sam sues Bob in New Hypoland for damages after a tree from Bob's property falls on Sam's car. The state court finds Bob not liable, citing a New Hypoland statute that absolves property owners from such damages if the tree was healthy and the fall was due to natural causes. Bob had argued that a federal environmental law encouraging the preservation of natural habitats should shield him from any liability. Result: The Supreme Court would not review the case because the decision rests on a state law that adequately supports the judgment. The federal environmental law Bob cites does not impact the state law's provisions on liability for naturally caused damages, making the federal issue irrelevant to the case's outcome.
Hypo 2: Sam sues Bob in New Hypoland's state court for breaching a contract that involves both state and federal environmental regulations. The state court rules in Sam's favor, citing federal environmental law errors made by Bob. Bob appeals to the Supreme Court, arguing the state court misinterpreted federal law. Result: The Supreme Court decides to review the case because it involves a state court's potential mistake in applying federal law, which falls within the Supreme Court's review scope.
Hypo 3: In Hypofornia, Bob sues a local newspaper owned by Sam for defamation, a case typically governed by state law. However, Bob argues that the case involves First Amendment rights, a federal issue. The state court decides based on Hypofornia's defamation laws without addressing the First Amendment claim. Bob appeals to the Supreme Court. Result: The Supreme Court may choose to hear the case since it involves the potential misapplication of federal constitutional law by the state court.
Hypo 4: Sam sues Bob in New Hypoland for damages after a tree from Bob's property falls on Sam's car. The state court finds Bob not liable, citing a New Hypoland statute that absolves property owners from such damages if the tree was healthy and the fall was due to natural causes. Bob had argued that a federal environmental law encouraging the preservation of natural habitats should shield him from any liability. Result: The Supreme Court would not review the case because the decision rests on a state law that adequately supports the judgment. The federal environmental law Bob cites does not impact the state law's provisions on liability for naturally caused damages, making the federal issue irrelevant to the case's outcome.
