Adequate and Independent State Ground Doctrine

Take a look at p. 57 of the casebook: "Corollary to the finality of state court interpretations of state law is the principle that issues of federal law resolved by state courts will not be reviewed by the Supreme Court if the state court's judgment rests upon an 'adequate and independent' state ground." What does that mean?

 

Suppose our client is an Amish farmer who is charged with driving a slow moving vehicle without displaying a bright orange warning sign. Our client refuses to display the sign because his religion commands him to live a plain and humble life, and bright orange signs are designed to call attention to the driver and his vehicle by being loud and colorful.

The case goes through the state courts (say, in Minnesota) and the Minnesota Supreme Court reverses our client's conviction under the motor vehicle laws based upon two grounds:

1. The Free Exercise Clause of the U.S.Constitution protects our client from a law that substantially burdens his religiously-compelled conduct;and

2. The religious freedom clause of the Minnesota state constitution protects our client's right to conduct himself based upon his religious conscience.

Suppose the Minnesota Supreme Court misinterpreted the Free Exercise Clause and erroneously held that it protects our client's right to drive without the orange sign. Does the U.S. Supreme Court have appellate jurisdiction to review the Minnesota Supreme Court's erroneous holding on a matter of federal law?

Now suppose that the Minnesota Supreme went the other way and:

1. rejected our client's Free Exercise claim;and

2. rejected our client's claim under the state constitution.

Does the U.S. Supreme Court have appellate jurisdiction to review the Minnesota Supreme Court's decision denying our client's Free Exercise claim? Or is the state law holding an adequate and independent ground for the judgment in the case?

Hint--if the state court's interpretation of the Free Exercise Clause is incorrect, would state law be an adequate basis for the judgment denying our client relief?