Since the advent of the Burger Court, Justice Brennan, among others, has noted and applauded the increasing tendency of those presenting civil libertarian claims to rely less on United States Supreme Court interpretation of the federal Constitution and more on state court readings of state constitutions. In much the same farewell-to-the-Warren-Court spirit, legal commentators have reviewed and indicated ways which state courts have, and might, base rulings on state constitutions. Scholarly interest has been revived in the one-hundred year old principle that the Supreme Court will not review state supreme court decisions based upon an independent and adequate state ground. The Burger Court's restriction of access to federal courts has led one federal judge to predict that state courts will assume increasing responsibility for defending federal rights. Techniques which state courts might employ to adjudicate federal claims have been canvassed.'