Michigan v. Long

Brief Fact Summary.

Defendant was convicted for possession of marijuana, but argued that the search that uncovered the marijuana was illegal.

Synopsis of Rule of Law.

The Supreme Court will not review judgments by state courts that include a plain statement that the decision rests on adequate and independent state grounds.

Facts.

David Long (Defendant) was convicted for possession of marijuana, found when police officers searched his vehicle. The police officers argued the search was necessary because they had reason to believe the dangerous weapons were in the vehicle. Defendant argued the search violated the Fourth Amendment and Michigan Constitution.

Issue.

Did the lower court’s decision rest on adequate and independent state grounds?

Held.

No, the lower court’s opinion rested on federal law.

Discussion.

The Court determined that it had jurisdiction because the lower court did not expressly rely on adequate and independent state grounds, mentioning both federal and state law in its opinion. The Court stated that, while case precedent had not developed a consistent approach to the problem, state court opinions that lacked a plain statement confirming they relied on independent rather than constitutional grounds could be reviewed.