mr. bernstein. >> mr. chief justice, and may it please the court. the issue is whether to decide the question of miller's retroactivity in this case or in a federal habeas case such as johnson versus mannis, number 15-1 on this court's docket. in today's case there is no jurisdiction over that question because the point is enforce the supremacy clause which states that when, quote, the laws of the united states, unquote, apply, quote, the judges -- these are the key words -- in every state shall be bound thereby. there is no such thing as supreme federal law that depends on whether a particular state voluntarily makes federal precedents binding. when a state does that, when a state voluntarily adopts non-binding federal precedents, that creates no right under federal law, which is what 1257 requires, and michigan versus long does not apply. >> how would you describe the adequate and independent state ground on which this decision rested? >> i would say that the lack of a binding federal law question