"[A]lthough in the past it might have been safe for counsel to raise only federal constitutional issues in state courts, plainly it would be most unwise these days not also to raise the state constitutional questions."
Rees, Charles A.
"State Constitutional Law for Maryland Lawyers: Individual Civil Rights,"
University of Baltimore Law Review: Vol. 7
, Article 4.
Available at: https://scholarworks.law.ubalt.edu/ublr/vol7/iss2/4