federal law as interchangeable in their advocacy in state courts. See State Constitutions in the Federal System at 49. Beginning in the 1960s, however, a growing number of states began to rediscover the independent nature of their state constitutional provisions. Sometimes called the “new judicial federalism,” the high courts of California, New York, New Jersey, Oregon, Washington, and Wisconsin were particularly active, followed by those of New Mexico, Indiana, Georgia, Ohio, Michigan, Connecticut, Minnesota, Utah, Pennsylvania, and many other states. The cases characterize the examination of independent state constitutional grounds by state courts not as some kind of aberration, but as a solemn duty. See, e.g., Burling v. Chandler, 148 N.H. 143, 804 A.2d 471, 476 (2002) (per curiam) (<HOLDING>); Commonwealth v. Gaffney, 557 Pa. 327, 733
holding that definition of seizure under state constitution differs from that under us constitution recognizing that provisions of the colorado constitution should be construed in the context of the constitution as a whole holding missouri constitution requires stricter separation of church and state than does federal constitution recognizing that oath taken to honor state constitution makes it the justices duty to apply the state constitution when it does not conflict with the federal constitution recognizing exception under state constitution