Michigan v. Long

Brief Fact Summary.

Long, the respondent, was convicted for possession of marijuana found by police in the passenger compartment of his automobile he was driving during weapons search under Terry, which held that police may validly search for weapons in the absence of probable cause to arrest.

Synopsis of Rule of Law.

When a state court decision fairly appears to rest primarily on federal law, and when the adequacy and independence of any possible state law ground is not clear from the face of the opinion, the Supreme Court will accept as the most reasonable explanation that the state court decided the case the way it did because it believed that federal law would require it to do so.

Facts.

In Terry v. Ohio, the Supreme Court upheld the validity of a protective search for weapons in the absence of probable cause to arrest because it is unreasonable to deny a police officer the right to neutralize the threat of physical harm when there is a suspicion that an individual is armed and dangerous. Long was convicted for possession of marijuana found by police in the passenger compartment of the car he was driving during weapons search under Terry. Long filed a motion to suppress the marijuana. The lower court denied but the Michigan Supreme Court reversed, holding that the search under Terry was not justified.

Issue.

Do federal courts have jurisdiction to a case if the decision below rests on an adequate and independent state grounds?

Held.

Yes, when a state court decision fairly appears to rest primarily on federal law, and when the adequacy and independence of any possible state law ground is not clear from the face of the opinion, the Supreme Court will accept as the most reasonable explanation that the state court decided the case the way it did because it believed that federal law would require it to do so.

Dissent.

Justice Stevens

Historically, where the state court’s judgment rests on two grounds, on involving a federal question and the other not, and the ground independent of a federal question is sufficient to sustain it, the Supreme Court will not take jurisdiction. Any rule adopted by this Court should show respect for state courts and a desire to avoid advisory opinions. It is also in the Court’s interest in the sound, efficient management of scarce federal judicial resources. If it is not apparent that this Court’s views would affect the outcome of a case where the state court has shown an adequate ground, this Court cannot interfere it.

Discussion.

The approach stated obviates the need to examine state law to decide the nature of the state court decision and avoid the danger of the Supreme Court’s rendering advisory opinions. It also avoids the unsatisfactory and intrusive practice of requiring state courts to clarify their decisions to the satisfaction of the Supreme Court. This way, state judges will have a clearer opportunity to develop state jurisprudence unimpeded by federal interference and yet will preserve the integrity of federal law.