Supreme Court of the United States · 1984 · Federal Courts
Federal Courtsadequate and independent state groundsunclear state court basisvacaturremandcertiorarifederal constitutional claimsstate court clarification
Facts
In a criminal trial, respondent entered an order barring the press and public from publishing the names and addresses of jurors. The order also prohibited the parties from sketching, photographing, televising, and videotaping jurors during their service in the criminal proceedings. In addition, the parties were forbidden from handling trial exhibits without permission of the court. Petitioners challenged that order in the Supreme Court of Pennsylvania, which denied their writ petition without opinion.
Issue
When a state supreme court denies relief without opinion, and the record does not show whether it rejected asserted federal constitutional claims or instead relied on an adequate and independent state ground, should the Supreme Court grant certiorari, vacate, and remand for clarification?
Rule
If the record does not disclose whether a state court passed on federal claims or denied relief on an adequate and independent state ground, the Supreme Court may grant certiorari, vacate the judgment, and remand for further proceedings to clarify the record.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, a trial judge entered an order limiting a neighborhood newspaper's access to certain courtroom materials during a pending criminal case. Desert Ledger Publishing filed an emergency petition in the Arizona Supreme Court arguing that the order violated the Federal Constitution, but the court denied relief in a one-line order without explanation.
If Desert Ledger seeks review in the U.S. Supreme Court, what is the most appropriate disposition?
Explanation. When the state-court record does not disclose whether the state court passed on the federal claims or instead denied relief on an adequate and independent state ground, the U.S. Supreme Court may grant certiorari, vacate, and remand for clarification. The Court does not decide the federal merits under that circumstance. (Derived from Capital Cities Media, Inc. v. Toole (1984).)