The U.S. Supreme Court has assertively reviewed decisions in which State tribunals expand criminal protections under the guise of State constitutions while relying on Federal law interpretations. Consequently, State courts wishing to provide criminal protections either unavailable under the Federal Constitution or no longer guaranteed by the U.S. Constitution or no longer guaranteed by the U.S. Supreme Court have turned to their State constitutions as a means of avoiding Federal review. The basis for this evasion technique is in the independent and adequate State ground doctrine. Under this doctrine, the U.S. Supreme Court generally declines to review a State decision based on either a State ground alone, constitutional or otherwise, or on both State and Federal grounds if resolution of the State law renders consideration of the Federal issue unnecessary. Since 1975, the New Jersey Supreme Court in three major search-and-seizure cases has rejected U.S. Supreme Court rulings and imposed greater restrictions on police activity under the State constitution. In arguing that this is inappropriate, given the similarity between New Jersey and Federal relevant constitutional provisions, < this article presents five suggestions to assist prosecutors in counteracting defendants' State constitutional claims. A total of 238 footnotes are listed.