When may the United States Supreme Court review a state court’s judgment on a federal question when the state decision rests on independent and adequate state grounds?

When may the United States Supreme Court review a state court’s judgment on a federal question when the state decision rests on independent and adequate state grounds?

• A. Always, regardless of state grounds.
• B. Only if there are no independent state grounds.
• C. Only if the state grounds are identical to federal law.
• D. Never, if independent state grounds exist.

Answer: (D)

The key idea is the independent and adequate state grounds doctrine. If a state court’s decision on a federal question rests on independent and adequate state grounds, the U.S. Supreme Court lacks jurisdiction to review the federal issue. In other words, when the state decision would stand even without any federal question because a separate, sufficient state basis determines the outcome, the federal question is not needed to decide the case, and the Court will not intervene. This explains why the correct approach is that the Supreme Court would not review the federal question if independent state grounds exist. If there were no independent state grounds, or if the state grounds were not adequate to sustain the result, the federal question could be reviewed. The other options fail because they ignore the crucial requirement that the state grounds be both independent and adequate to foreclose Supreme Court review.

The key idea is the independent and adequate state grounds doctrine. If a state court’s decision on a federal question rests on independent and adequate state grounds, the U.S. Supreme Court lacks jurisdiction to review the federal issue. In other words, when the state decision would stand even without any federal question because a separate, sufficient state basis determines the outcome, the federal question is not needed to decide the case, and the Court will not intervene.

This explains why the correct approach is that the Supreme Court would not review the federal question if independent state grounds exist. If there were no independent state grounds, or if the state grounds were not adequate to sustain the result, the federal question could be reviewed. The other options fail because they ignore the crucial requirement that the state grounds be both independent and adequate to foreclose Supreme Court review.