The new federalism in state constitutional interpretation is alive and well when it comes to the law of search and seizure — even, to some extent, in states that have pegged their Fourth Amendment analogues to federal law. In a recent article, I examined the ability of each state high court to be its own interpreter, potentially reading its respective constitution to be more rights protective than the federal Fourth Amendment. ...

But are there states in which this simply cannot be? Are there states in which the U.S. Supreme Court interpretation of the Fourth Amendment is binding as state constitutional law, no matter what a state’s own supreme court justices might wish? In other words, are there states necessarily in “lockstep” with the federal Fourth Amendment?

Sort of. Allow me to explain that lawyerly answer. ...