MICHIGAN V. LONG
463 U.S. 1032 (1983)
NATURE OF THE CASE: This case sets forth the limitations on federal judicial review of
state court decisions.
FACTS: The Michigan State Supreme Court reversed Defendant Long's conviction of illegal
possession of marijuana. The state court found that Long's conviction directly resulted from
evidence obtained through an unreasonable search or seizure in violation of the Fourth
Amendment. As 'fruit' of poisonous tree, the damaging evidence was inadmissible against the
Defendant. However, the state continued to pursue admissibility of the evidence in the
United States Supreme Court to convict the Defendant. The Defendant contested, asserting
that federal judicial review was unavailable to the U.S. Supreme Court to overturn his
conviction because the state's decision had been rendered on 'adequate and independent
grounds.' In addition, the Defendant argued that Michigan's unlawful search and seizure
provisions are more expansive than federal Fourth Amendment protection. Nevertheless, the
state court heavily relied on federal Fourth Amendment law in rendering its decision in
favor the Defendant. In this opinion, the U.S. States Supreme Court reverses the decision of
the state court. (See more on Terry issue below).
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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