(3) State courts, however, could avoid Supreme Court review if that court provides a plain statement indicating that the decision rests on adequate and independent state grounds. (4)
City of Memphis (13) the United States Supreme Court first held that it would not review a decision of the highest state court where that decision was based on adequate and independent state grounds. (14) State constitutional law scholars have suggested that there are at least three reasons for the Supreme Court's adoption of the adequate and independent state grounds doctrine.
Long's assertion that the Court was without jurisdiction to hear the case because the decision of the Michigan Supreme Court rested on adequate and independent state grounds. The Court first examined the principles the Court had previously used to determine whether references to state law constitute adequate and independent state grounds.
The Labron and Class cases are special because both the Pennsylvania Supreme Court and the Court of Appeals of New York are essentially the only courts to openly criticize the United States Supreme Court for concluding that these respective cases were not based on adequate and independent state grounds. Most state courts that disagree with the Supreme Court take more reserved and deferential approach.
at nn.30-31 (explaining the meaning of judicial economy, comity, and jurisdiction in the setting of how each justified the creation of the adequate and independent state grounds doctrine).