In topology a Mobius strip is a one-sided surface formed by holding one end of a rectangle fixed, rotating the opposite end 180 degrees, and joining the two ends.'In Supreme Court jurisdiction the independent and adequate state ground doctrine forms a similar figure by joining, on one side, the power of the Court to revise the judgments of state courts on issues of federal law with, on the other side, the Court's lack of any general power to re examine issues of state law.
Thomas E. Baker,
The Ambiguous Independent and Adequate State Ground in Criminal Cases: Federalism Along a Mobius Strip
, 19 Ga. L. Rev. 799
Available at: http://ecollections.law.fiu.edu/faculty_publications/178