Also known as: adequate and independent state grounds · adequately and independently · AIG · adequate independent state grounds
Written by attorneys · grounded in primary & secondary sources — see below
A jurisdictional doctrine that precludes Supreme Court review of a state court judgment when that judgment rests on state law grounds sufficient to support the result and independent of federal law. The Supreme Court presumes jurisdiction and treats the decision as resting on federal law unless the state court clearly and expressly states that its judgment rests on independent state grounds.
Adam Anderson appealed his conviction to the state supreme court. The court rejected his federal constitutional claim after noting that he had omitted the issue from his new-trial motion. Because the opinion did not expressly declare that the waiver ruling stood apart from federal law, the Supreme Court assumed jurisdiction and reached the merits.
Abigail Alvarez was convicted under a federal statute for possessing a firearm near a school. The state appellate court upheld the conviction on both Commerce Clause and state-law alternative grounds. Because the opinion did not clearly separate the state ground from federal analysis, the Supreme Court exercised jurisdiction.
Select any source to read its text and confirm it supports the definition.
Antonio Alvarado requested a court-appointed psychiatrist to assist his insanity defense. The state court denied the request and later held that the claim was waived because it was not renewed in the new-trial motion. The opinion cited both state precedent and federal due-process principles without clearly separating them, so the Supreme Court reviewed the federal issue.
Alice Atkins sought to introduce expert testimony on mental illness to negate mens rea. The state court of appeals rejected the claim on the merits without mentioning any procedural bar. The Supreme Court therefore treated the decision as resting on federal law and exercised review.
Alexandra Armstrong was questioned after requesting counsel. The state court upheld admission of her statements by applying both the federal Edwards rule and a parallel state doctrine. Because the opinion did not expressly rely on the state ground alone, the Supreme Court assumed jurisdiction over the federal claim.
Ava Adebayo argued in state postconviction proceedings that she was entitled to appointed counsel. The state court denied relief citing both federal precedent and an independent state procedural rule. Because the opinion did not clearly and expressly rest on the state ground, the Supreme Court proceeded to the merits.
The Court presumes jurisdiction when the state opinion does not clearly and expressly state that its judgment rests on adequate and independent state grounds. This presumption treats the decision as resting on federal law.
The Supreme Court exercises jurisdiction because the opinion does not clearly rest on an independent state ground. The federal claim remains reviewable.
No. A procedural default bars review only when the state court clearly and expressly relies on the state procedural rule as an adequate and independent ground. Ambiguous opinions trigger the presumption of jurisdiction.
…rules for determining the primacy of state law, see, e. g. , Erie R. Co. v. Tompkins , 304 U. S. 64 (1938), the doctrine of adequate and independent state grounds, see, e. g. , Murdock v. Memphis , 20 Wall. 590 (1875); Michigan v. Long , 463 U. S. 1032 (1983), the whole jurisprudence of pre-emption, see, e. g. , Rice v. Santa Fe Elevator Corp. ,…