28
MOORE v. HARPER
Opinion of the Court
constitutional rights.” NAACP v. Alabama ex rel. Patterson, 357 U. S. 449, 457–458 (1958).
Running through each of these examples is the concern
that state courts might read state law in such a manner as
to circumvent federal constitutional provisions. Therefore,
although mindful of the general rule of accepting state court
interpretations of state law, we have tempered such deference when required by our duty to safeguard limits imposed
by the Federal Constitution.
Members of this Court last discussed the outer bounds of
state court review in the present context in Bush v. Gore,
531 U. S. 98 (2000) (per curiam). Our decision in that case
turned on an application of the Equal Protection Clause of
the Fourteenth Amendment. Id., at 104–105. In separate
writings, several Justices addressed whether Florida’s Supreme Court, in construing provisions of Florida statutory
law, exceeded the bounds of ordinary judicial review to an
extent that its interpretation violated the Electors Clause.
Chief Justice Rehnquist, joined in a concurring opinion
by JUSTICE THOMAS and Justice Scalia, acknowledged the
usual deference we afford state court interpretations of
state law, but noted “areas in which the Constitution requires this Court to undertake an independent, if still deferential, analysis of state law.” Id., at 114. He declined to
give effect to interpretations of Florida election laws by the
Florida Supreme Court that “impermissibly distorted them
beyond what a fair reading required.” Id., at 115. Justice
Souter, for his part, considered whether a state court interpretation “transcends the limits of reasonable statutory interpretation to the point of supplanting the statute enacted
by the ‘legislature’ within the meaning of Article II.” Id., at
133 (Souter, J., joined by Stevens, Ginsburg, and Breyer,
JJ., dissenting).
We do not adopt these or any other test by which we can
measure state court interpretations of state law in cases implicating the Elections Clause. The questions presented in
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