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Legal Definitions - Nonfederal grounds
Definition of Nonfederal grounds
Nonfederal grounds refers to a situation where a state court's decision in a legal case is based entirely on its own state's constitution, statutes, or common law, rather than on the U.S. Constitution or federal laws. When a state court's judgment is supported by such "adequate and independent state grounds," the U.S. Supreme Court generally lacks the authority (jurisdiction) to review that decision. This principle ensures that the U.S. Supreme Court only reviews cases that involve questions of federal law, leaving state courts as the final arbiters of purely state law matters.
Here are some examples illustrating "nonfederal grounds":
State Environmental Regulation: A state environmental agency fines a manufacturing company for violating a specific state law regarding industrial waste disposal. The company appeals the fine through the state court system, arguing that the state agency misinterpreted the state statute. The state's highest court ultimately upholds the fine, providing a definitive interpretation of the *state's* environmental protection law.
This decision rests entirely on the interpretation and application of a *state* environmental statute. There is no claim that the state law itself violates federal environmental regulations or the U.S. Constitution. Therefore, the state supreme court's judgment is based on "nonfederal grounds," meaning the U.S. Supreme Court would not have jurisdiction to review it.
Broader State Constitutional Rights: A defendant in a state criminal trial argues that evidence used against them was obtained through an illegal search under the *state's constitution*. The state's highest court agrees, ruling that the search violated a provision of the *state constitution* that provides greater protection against searches than the Fourth Amendment of the U.S. Constitution. The state court explicitly states that its decision is based *solely* on its interpretation of the state constitution.
Even though there is a similar federal constitutional right (the Fourth Amendment), the state court's decision is explicitly and independently grounded in its *state constitution*. Because the state court's ruling provides a broader protection based purely on state law, it constitutes "nonfederal grounds," preventing the U.S. Supreme Court from reviewing the state court's interpretation of its own constitution.
Pure State Property Dispute: Two neighbors in a rural area have a long-standing dispute over the exact boundary line between their properties. The dispute involves interpreting old deeds, local land survey records, and state property law precedents. The case proceeds through the state court system, and the state's highest court issues a final ruling establishing the boundary based on *state property statutes* and common law principles.
This entire case revolves around the application of *state property law*. There are no federal statutes, constitutional provisions, or treaties involved in determining the property line. The state court's decision is therefore based on "nonfederal grounds," meaning the U.S. Supreme Court would not have the authority to review the state court's interpretation of its own state's property law.
Simple Definition
Nonfederal grounds refer to the basis of a state court's decision that rests entirely on state law, rather than federal law. The U.S. Supreme Court will not review a state court judgment if it finds these "adequate and independent state grounds" are sufficient to support the decision, even if federal issues were also present in the case.