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absent a clear statement to the contrary by the state
court. Michigan v. Long, 463 U.S. 1032, 1040 (1983).
But the opposite presumption applies “[i]n the absence
of a clear indication that a state court rested its decision on federal law. . . .” Coleman, 501 U.S. at 739–40.
“That presumption grows out of the principle that
there must be some affirmative showing that a federal
question was presented to the state court and that a
decision on such question was necessary to a determination of the cause.” Stephen M. Shapiro, et al., Supreme Court Practice 213 (10th ed. 2013).
In cases such as this, “ ‘[w]here the highest court
of the state delivers no opinion and it appears that the
judgment might have rested upon a nonfederal ground,
this Court will not take jurisdiction to review that
judgment.’ ” Durley v. Mayo, 351 U.S. 277, 281 (1956)
(quoting Stembridge v. Georgia, 343 U.S. 541, 547
(1952)). Petitioners argue that it is never permissible
for a state court to rule on a fee motion brought under
42 U.S.C. 1988 without also issuing an opinion, but
they are mistaken. Pet. 16–17. While Petitioners may
find it preferable for state courts to issue opinions each
time they rule on a motion, this Court has recognized
that “federal courts have no authority to impose mandatory opinion-writing standards on state courts. . . .”
Johnson v. Williams, 568 U.S. 289, 300 (2013). This is
especially true where a state court summarily denies a
motion due to a party’s procedural default.