adequate and independent state grounds

Adequate and independent state grounds is a doctrine that limits the U.S. Supreme Court’s jurisdiction to review state court judgments. The Court will review a state court decision only if the judgment rests on a federal question and the resolution of that question is necessary to the outcome. If the judgment is supported by adequate and independent state law grounds, the Court will not exercise jurisdiction.

• A state ground is considered adequate when it is a well-established and consistently applied rule of state law that fully supports the judgment, making the outcome valid even without reference to federal law. 
• A state ground is independent when it rests solely on state law and does not depend on, or incorporate, federal law in its reasoning. 

If the state court clearly rests its decision on both federal and state grounds, and the state ground alone is sufficient to support the judgment, the Supreme Court lacks authority to review it. This doctrine reflects principles of federalism and judicial restraint, ensuring that state courts remain the final arbiters of state law.

A leading explanation is provided in Michigan v. Long, 463 U.S. 1032 (1983), where the Court held that if a state court decision appears to rest primarily on federal law or is interwoven with federal law, the Supreme Court will assume jurisdiction unless the state court explicitly states that its decision rests on “adequate and independent state grounds.”

See also: Republican Nat. Committee v. Burton, 455 U.S. 1301 (1982).

[Last reviewed in October of 2025 by the Wex Definitions Team] 

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