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Michigan v. Long

Deciding The Court's Jurisdiction

Long argued that the Supreme Court had no reason to hear the case. The Michigan Supreme Court had followed an accepted precedent, basing its decision on "adequate and independent state grounds," i.e., the protection provided by the state's constitution. Before addressing the constitutional issues of the case, the Supreme Court looked at Long's claim.

Writing for the 5-4 majority, Justice O'Connor asserted that the state court had not relied on state grounds. The lower court, she wrote, had relied almost exclusively on federal cases, especially Terry, in its decision: "The references to the State Constitution in no way indicate that the decision below rested on grounds in any way independent from the state court's interpretation of federal law."

O'Connor had previously set forth the new, general standard the Court would apply when deciding to hear similar cases:

If a state court chooses merely to rely on federal precedents as it would on the precedents of all other jurisdictions, then it need only make clear by a plain statement in its judgment or opinion that the federal cases are being used only for the purpose of guidance, and do not themselves compel the result that the court has reached . . . If the state court decision indicates clearly and expressly that it is . . . based on bona fide separate, adequate, and independent grounds, we, of course, will not undertake to review the decision.
The Court then proceeded to address the validity of a Terry search on a car and upheld it as constitutional. Officers could search the areas of a car where a weapon could be hidden, if they believed the suspect was dangerous and might gain control of a hidden weapon.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1981 to 1988Michigan v. Long - Significance, Deciding The Court's Jurisdiction, Reaction To The "plain Statement" Rule