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The federal statute admitting a particular state to the Union granted the state certain public lands, and established some very ambiguous conditions on the subsequent disposition of these lands by the state. This federal statute also required the new state to write those exact same conditions into its state constitution. One hundred years later, a statute of the state dealing with the sale of these public lands was challenged in a state court lawsuit on the ground that it was inconsistent with the conditions contained in the federal statute, and with the provisions of the state constitution that exactly copy the conditions contained in the federal statute. The trial court decision in this case was appealed to the state supreme court. In its opinion, the state supreme court dealt at length with the ambiguous language of the federal statute and with cases interpreting identical language in federal statutes admitting other states to the union. The state supreme court opinion did not discuss the similar provisions of the state constitution, but it did hold that the challenged state statute is invalid because it is «inconsistent with the language of the federal statute and therefore is inconsistent with the identical provisions of our state constitution.»
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The Court may determine whether a state court has reached a decision that is not in conformity with the Constitution, but it may not review state court decisions that merely adjudicate questions of state law because the Court's review of state court judgments is limited to questions of federal law.
Even if there is a federal question in the state court case, the Court may not review it if there is an «independent and adequate» state ground for the state court's decision. That is, if the same result would be reached even had the state court made a different decision on the federal question, the Court may not decide the case. This is because its opinion would in effect be an «advisory» one.
A state court may hold that a state statute violates both the state and federal legal provisions. A holding that the state constitution is violated may be achieved in one of two ways: (i) the state court may have independently interpreted the state constitutional provision, without relying directly on federal cases construing the federal provision; or (ii) the state court may have interpreted the state constitutional provision as being co-extensive with the comparable federal provision, and then attempted to follow the relevant federal case law. In that context, the Court may find that an independent and adequate state ground did not exist, allowing the Court to review it. However, the mere fact that a federal question is involved in a case is not sufficient to entitle the Court to review it. And, even if the Court is entitled to review a case, it will generally adjudicate only the federal issues.
A is correct. The Court may not review the state court's interpretation of its own state constitution, but here, the state court rested its decision on interpretation of federal law. Its comment that the decision also comported with the same provision in the state constitution, without any interpretation, was not an «independent and adequate» state ground that would require the Court to decline to review the case. This is because when a state court interprets state and federal provisions co-extensively, the Court may decide to hear the case as to the federal issues. Therefore, the Court should accept the case for review and determine the validity and interpretation of the federal statute if it raises an important federal question.
B is incorrect. Based on the fact that the state constitution and federal statutory provision are identical and the state court interpreted them co-extensively, it would serve no purpose to ask the state supreme court for clarification.
C is incorrect. As explained above, the state court opinion did not provide an independent and adequate state ground for the decision given that it rested on an identical interpretation of the state and federal provisions.
D is incorrect. The issue revolves around the interpretation of a federal statute, which is plainly within the U.S. Supreme Court's jurisdiction established by Article III to exercise judicial power over all «cases and controversies» arising under the Constitution, laws, or treaties of the U.S.