(concurring in result).
[¶ 31.] Do South Dakota residents have a reasonable expectation of privacy in the trash they set on the curbside for disposal, and if so, must the police have a warrant to search it? In interpreting the Fourth Amendment, the United States Supreme Court has answered these questions in the negative. Nonetheless, we are not bound to discern the same meaning in our State Constitution as the Supreme Court finds in *438the Federal Constitution.4 On the other hand, we cannot simply assume that our Constitution mandates greater protections than those available under the Federal Constitution. Whether we can more broadly interpret our similarly worded state constitutional provisions should be decided on a neutral set of divergence standards.
[¶ 32.] As judges, we took an oath to uphold both our State and Federal Constitutions. In the proper case, therefore, this Court has the obligation to decide whether the South Dakota Constitution requires stricter standards on searches and seizures than those required by the United States Constitution. See Cooper v. California, 386 U.S. 58, 62, 87 S.Ct. 788, 791, 17 L.Ed.2d 730 (1967). The Tenth Amendment provides that “[t]he powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.” U.S. Const, amend. X.
[¶ 33.] A minority of states, under their constitutions, have recognized a reasonable expectation of privacy in curbside trash. It is an open question in South Dakota. For now, it should remain open. As important as the question is, there are three reasons why we should not address it here. First, the only argument counsel for the defendants puts forth is that a few other states have recognized a privacy interest in curbside trash, and, therefore, we should too. How other state courts approach the task of interpreting their own constitutions may be helpful, but those decisions should not steer our constitutional jurisprudence. South Dakota’s Constitution stands on its own. If we are to apply a truly independent and authentic analysis, we must adopt an interpretive methodology based on the unique text of our Constitution and its historical underpinnings. Only when we address these questions autonomously can we develop a coherent body of South Dakota constitutional law. Indiscriminate borrowing of other state constitutional decisions invites haphazard and result-oriented jurisprudence. Expediency has no place in principled constitutional interpretation.
[¶ 34.] Second, just as the meaning of a state constitutional provision should not be dependent on the meaning of its federal counterpart, so also we must not bow to the notion that the meaning must always be different. No credence lies in the perfunctory argument that because we have a separate search and seizure clause it must therefore provide for greater protections. At a minimum, citizens have the rights guaranteed by the federal provisions, but some of our state constitutional guarantees might afford only equal or less protection than the Federal Constitution. Nor is it sufficient to argue that we should reinterpret a provision of our Constitution based on mere disagreement with Supreme Court analysis of a similar provision. Without more, such disagreement imparts no sound doctrinal basis to impose a contrary view under the pretext of separately interpreting our State Constitution. Our Constitution is more than just a device to reject or evade federal decisions with which we disagree.
*439[¶ 35.] Third, matters essential to making an informed decision here were not developed at trial or were only brought up for the first time on appeal. At oral argument, defense counsel, in support of his privacy argument, broached the Brookings City Ordinance on garbage collection. The ordinance had not been offered or admitted in the court below and thus we are not able to consider it here. Coyote Flats, L.L.C. v. Sanborn County Comm’n, 1999 SD 87, ¶ 9, n. 5, 596 N.W.2d 347, 350 n. 5 (citations omitted). Yet, that ordinance might well have been relevant to our consideration. It may have given some insight into community expectations about garbage collection. See Rikard v. State, 354 Ark. 345, 123 S.W.3d 114, 121 (2003) (intent behind city ordinance considered on whether it created citizen expectation of privacy in garbage).
[¶ 36.] With an inadequate legal argument and an incomplete record, the question of privacy in curbside garbage should remain open until the matter is thoroughly briefed and supported in some future case. Other courts have likewise declined to address state constitutional arguments when they were inadequately briefed. Cf. State v. Brett, 126 Wash.2d 136, 892 P.2d 29, 41 (1995) (declining to decide defendant’s right to impartial jury under State Constitution because factors previously declared necessary for rational argument were not presented), cert. denied, 516 U.S. 1121, 116 S.Ct. 931, 133 L.Ed.2d 858 (1996); State v. Wethered, 110 Wash.2d 466, 755 P.2d 797, 800-01 (1988). See also Robert F. Utter, The Practice of Principled Decision-Making in State Constitutionalism: Washington’s Experience, 65 Temp L. Rev. 1153, 1161-63 (1992). For these reasons, the circuit court’s decision should stand.
I.
[¶ 37.] When the texts of parallel state and federal provisions are the same, and no other interpretive principles guide us toward a different understanding, do we accept the Supreme Court’s interpretation, or do we seek our own? Before a state constitutional provision may be read more broadly than its similarly worded federal counterpart, should there be unique and compelling state reasons for doing so? Might we envision uniformity in state and federal search and seizure law, or are we bound to expand individual rights in cases where the federal courts provide only minimal protections? In answer to these questions, we might say that generally a level of uniformity in federal and state law is desirable. Widely divergent interpretations of similar provisions create unpredictability and confusion in the law.5 Given that many of our state constitutional provisions similar or identical to corresponding federal provisions were obviously patterned after the Federal Constitution, decisions from the Supreme Court interpreting those provisions deserve some deference in state constitutional analysis. In the end, however, these questions can only be answered in the unique circumstances of each case, and they must be answered in a principled way.
[¶ 38.] Our analysis of South Dakota’s Constitution should be no less rigorous than the Supreme Court’s analysis of the Federal Constitution. When arguing that a provision of our Constitution should be *440interpreted differently from a cognate federal provision, counsel must undertake a thorough examination, using recognized standards by which we may determine that a genuine reason exists to diverge from the federal interpretation.6 Only with worthy advocacy can we perform our function as jurists to reach a principled basis for deciding when and how to resolve state constitutional claims.
[¶ 39.] There is another reason why we must insist on reasoned advocacy. On at least two prior occasions, this Court, in interpreting our State Constitution, has afforded criminal defendants greater protections than those recognized by the Supreme Court under the Federal Constitution. State v. Opperman, 247 N.W.2d 673 (S.D.1976) (inventory search valid under Federal Constitution, declared invalid under state constitution); Parham v. Municipal Court, 86 S.D. 531, 199 N.W.2d 501 (1972) (impliedly State Constitution required jury trial for municipal offense, although Federal Constitution did not require it). Neither decision ventures any state constitutional criteria for justifying its result.7 In Opperman, for example, the Court simply declared: “We find that logic and a sound regard for the purposes of the protection afforded by S.D. Const., Art. VI, § 11 warrant a higher standard of protection for the individual in this instance than the United States Supreme Court found necessary under the Fourth Amendment.” 247 N.W.2d at 675. What logic and what purpose did the Court find, and where?
[¶ 40.] Ungrounded in any interpretive method of analysis, Parham and Opper-man retain a tenuous hold on continued vitality. Although the ultimate holdings of these cases may still prevail in some form, certainly a citation to them as authority for a broader reading of our State Constitution will not suffice today. Since those cases were decided, state courts can now be reversed if they merely advert to their constitutions as a basis for holding contrary to the Supreme Court’s interpretation of the United States Constitution. Michigan v. Long, 463 U.S. 1032, 1041, 103 S.Ct. 3469, 3476-77, 77 L.Ed.2d 1201 (1983). In Long, the Court held that it would consider a state court decision to rest on state grounds only if it “indicates clearly and expressly that it is alternatively based on bona fide separate, adequate, and independent grounds.... ” Id. Decisions like Opperman were groundbreaking efforts into what was called the new judicial federalism.8 Today, we must build on their beginnings to create a coherent and systematic method of state constitutional interpretation.
II.
[¶ 41.] As a means of developing an “adequate and independent” basis for our state constitutional jurisprudence, the following are suggested nonexclusive divergence standards for claims of enhanced protection under the South Dakota Constitution. In deciding whether a state constitutional provision should receive a divergent interpretation, we should examine (1) the text of the provision at issue; (2) the territorial, legal, and constitutional history surrounding the provision; (3) the structural differences in the State and Federal Constitutions; and (4) the matters of unique state tradition or concern that bear on the meaning of the provision. There *441may be other helpful interpretive principles, depending on the nature of the case.9
1. Constitutional Text
[¶ 42.] Constitutional analysis always begins with the text. In many respects, South Dakota’s Constitution is a unique document with a meaning that must be derived through independent analysis of the document itself. We presume that each provision was crafted “with the utmost care and precision in the use of language, and with a full understanding of the accepted meaning of every word used therein.” McCoy v. Handlin, 35 S.D. 487, 153 N.W. 361, 372 (1915). If possible, we construe its language in accord with its plain meaning. Poppen v. Walker, 520 N.W.2d 238, 242 (S.D.1994). “In the absence of ambiguity, the language in the [Constitution must be applied as it reads.” In re Janklow, 530 N.W.2d 367, 370 (S.D.1995) (citation omitted). Analysis of the language includes the words themselves, their relationship to each other, and their context.
[¶ 43.] At the time our State Constitution was adopted in 1889, the Federal Bill of Rights had no binding effect on state courts. Fourth Amendment rights applied only in federal courts. It was not until the middle of the Twentieth Century, following a series of Supreme Court decisions, that most of the Federal Bill of Rights became applicable to the states by incorporation through the Fourteenth Amendment. Thus, the adoption of many of the provisions of our State Bill of Rights in the Nineteenth Century may have reflected an intention primarily to duplicate corresponding federal provisions. On the other hand, there may have been an intent behind some particular provisions to confer greater protections under state government than that afforded under the Federal Constitution.
[¶ 44.] The best argument for interpreting our State Constitution differently from the Federal Constitution is that the texts of the parallel provisions are different. There may be valid reasons why the drafters of our State Constitution wanted a provision to be understood more expansively than the drafters of our Federal Constitution, and a different wording would have made that clear. Thus, we should be alert to the ways in which the State and Federal Constitutions differ from each other.
[¶ 45.] In some instances, provisions in our Constitution have no true federal counterpart. Witness the fact that South Dakota was the first state to create direct, participatory power by its citizens in the legislative process. S.D. Const., Art. III, § 1; SDDS, Inc. v. State, 1997 SD 114, ¶ 15 n. 9, 569 N.W.2d 289, 293-94 n. 9 (citations omitted). For another cogent example, one need only look at the freedom of worship provision in Article VI, § 3, which begins, “The right to worship God according to the dictates of conscience shall never be infringed.” S.D. Const., Art. VI, § 3. This section goes on to detail the rights and limitations associated with the freedom of worship. Contrast that provision with the brief mention of the similar right in the First Amendment. These unique provisions strongly suggest an intent to supplement or enhance the *442rights granted under the Federal Constitution.
[¶ 46.] On the other hand, the provision at issue here, Article VI, § 11, is structurally and substantively identical to the Fourth Amendment. See Opperman, 247 N.W.2d at 674 (“almost identical”); City of Sioux Falls v. Walser, 45 S.D. 417, 187 N.W. 821, 822 (1922) (“in effect the same”). Nothing in the language itself indicates that the framers intended the state prohibition against unreasonable searches and seizures to be broader than the federal prohibition in the Fourth Amendment. Yet, with specific reference to the Fourth Amendment, we must recognize that courts have wrestled for decades over its meaning and scope. With its high level of generality, plain meaning analysis may not fully help to define the precise scope of Article VI, § 11. This brings us to the next criterion for interpretation.
2. Historical Circumstances
[¶ 47.] When the plain meaning and scope of constitutional provisions cannot be ascertained by simple resort to the text, it may be illuminating to uncover the principles and values that animated the framers. These underlying values may explain why a particular provision was adopted and why it may have been intended to carry a broader reach than its federal counterpart. To find these values, we can seek clues in the laws existing before adoption of the South Dakota Constitution.
[¶ 48.] Diligent counsel will examine such documents as the Organic Law of 1861, the Enabling Act of 1889, the various territorial codes, and any associated laws and judicial decisions interpreting them to unearth relevant history that might shed light on the reason for adopting the constitutional provision at issue.10 The territorial codes, for example, in existence before statehood, may reveal the concerns of citizens long before they were addressed in constitutional provisions. Of course, the records and debates of the South Dakota Constitutional Conventions of 1883, 1885, 1887, and 1889 may assist in understanding a provision.11 In many instances, the framers of our Constitution borrowed provisions from other state constitutions. The reasons for the adoption of these provisions in other states might give insight on why they were adopted in South Dakota.12 Moreover, legislation enacted shortly after the Constitution was adopted might suggest the purposes behind a constitutional provision.
[¶ 49.] Early decisions in this Court interpreting our State Constitution may also be helpful, especially in cases where a member of the Court had also been a delegate in one or more of the constitutional conventions leading up to the adoption of our Constitution. In the case of In re Davis, 2004 SD 70, ¶ 12 n. 1, 681 N.W.2d *443452, 456 n. 1, we noted that Judge Deigh-ton Corson was a delegate to both the 1885 and 1889 constitutional conventions and his joining in a decision was a likely indication of his accordant understanding of a constitutional provision.13 One should not overlook, of course, the 115 years of judicial decisions in this Court.
3. Structural Differences
[¶ 50.] Unlike the Federal Constitution, which grants enumerated powers to the federal government, our State Constitution limits the power of state government. State v. Hy Vee Food Stores, Inc., 533 N.W.2d 147, 148 (S.D.1995); State ex rel. Wagner v. Summers, 33 S.D. 40, 144 N.W. 730, 732 (1913). Under this limitation doctrine, in deciding whether a statute is constitutional, a specific constitutional provision must prohibit enactment of a statute rather than grant authority for its enactment. In re Heartland Consumers Power Dist., 85 S.D. 205, 209, 180 N.W.2d 398, 400 (1970). Accordingly, an explicit statement of rights in our State Constitution might be understood as a guaranty of those rights, not a restriction on them. Cf. Gunwall, 720 P.2d at 815. Where a provision is placed in the structure of the Constitution may also be instructive.
[¶ 51.] Although we should usually presume that similar provisions in our State and Federal Constitutions deserve similar interpretations, there may be principled reasons for coming to a conclusion different from the Supreme Court. “[I]f the state court deals with federal precedent and persuasively demonstrates that federal court reasoning is unacceptable, its result can no more be called unprincipled than can the original federal holding.” CHARLES H. WHITEBREAD & CHRISTOPHER SLOBOGIN, CRIMINAL PROCEDURE, AN ANALYSIS OF CASES AND CONCEPTS § 34.03, at 1038 (4th ed. 2000). Our Constitution should never become mere surplusage, but the burden of proving the unacceptability of the federal reasoning should bear heavily on the one challenging it.
4. Matters of Unique State Tradition or Concern
[¶ 52.] South Dakota retains a distinctly individual character, evident in its diverse communities, its amalgam of cultures, its mixture of heritages, and its contrasting terrain. Matters unique to South Dakota may generate a reason to view a particular constitutional provision differently. It should be the rare case, however, that this factor alone would cause us to reach a conclusion divergent from federal interpretation of a similarly worded constitutional provision. South Dakota is unique in many respects, but on issues of search and seizure, for example, we are not so different from most other states. Although not based primarily on a constitutional provision, our decision in Parks v. Cooper exhibits the type of deeply rooted regional issue — preservation of precious water resources through the public trust doctrine — that a court might take into account in examining a disputed provision of our constitution. 2004 SD 27, 676 N.W.2d 823.
[¶ 53.] In reference to the question of trash searches, “[expectations of privacy are established by general social norms,” and thus, we must ask how local norms in *444South Dakota differ from the rest of the country. See Robbins v. California, 453 U.S. 420, 428, 101 S.Ct. 2841, 2847, 69 L.Ed.2d 744 (1981) (exemplifying the dissimilar decisions throughout the country due to the refusal of later court opinions to follow its rationale). The Fourth Amendment was created to address government abuses perceived or actually experienced by the framers. Is a similar abuse occurring in South Dakota? The defendants do not make that assertion. In this case, the police were not searching residential garbage as a general crime control measure; they had a specific reason to examine the defendants’ trash. Although a few courts have found an expectation of privacy in curbside trash, a majority of state courts have found to the contrary. Do we have a culture or tradition in common with the minority of jurisdictions favoring a privacy interest in discarded trash?
[¶ 54.] In the end, this factor should be invoked cautiously. First, we can presume that in most instances the Legislature would enact laws dealing with matters of deep concern in South Dakota. Indeed, it could regulate trash searches if public distress about privacy reached a high level of concern. Second, this criterion has a high potential for misuse. What we may personally conceive as a matter of state tradition or concern may well be borne from our own strident viewpoint. We must remain mindful of Justice Frankfurter’s admonition that we are “not justified in writing [our] private notions of policy into the Constitution, no matter how deeply [we] may cherish them or how mischievous [we] may deem their disregard.” West Virginia State Bd. of Ed. v. Barnette, 319 U.S. 624, 647, 63 S.Ct. 1178, 1189, 87 L.Ed. 1628 (1943) (Frankfurter, J., dissenting).
Ill
[¶ 55.] Long ago, Justice Whiting, in a unanimous opinion of this Court, reflected that the Fourth and Fifth Amendments to the Federal Constitution are “in effect the same” as Article VI, §§ 9 and 11 of our State Constitution. Walser, 45 S.D. 417, 187 N.W. at 822. And though federal court decisions on the meaning and effect of the federal amendments are not controlling upon state courts in the construction of similar provisions in state constitutions, yet, “if we should find that the federal decisions are in conflict with a decision of this court, we should hesitate to follow our decision rather than those of a tribunal whose decisions are entitled to such consideration as those of the Supreme Court of our land.” Id. In those days, the Federal Constitution was interpreted in some respects to grant greater protection in federal prosecutions than our State Constitution was interpreted to grant in state prosecutions. This Court would later adopt Justice Whiting’s view. It decided to interpret our Constitution to afford protections commensurate with the Federal Constitution. State v. Gooder, 57 S.D. 619, 234 N.W. 610 (1930) (superseded by statute; however, the statute was later deemed unconstitutional).14 In the law’s vicissitudes, circumstances have changed, and we are now at another crossroad.
[¶ 56.] Whichever direction we decide to turn, we must remain aware of our limitations. Even if we were to conclude that there is a reasonable expectation of privacy in curbside garbage, finding expanded protection under our state search and seizure clause will provide no panacea *445against law enforcement excesses. In fact, our interpretation of the South Dakota Constitution will have no binding effect on federal law enforcement. It would not preclude federal agents from seizing garbage from South Dakota residents and using whatever evidence of a crime it revealed to prosecute the owners in federal court.15 Nor, for that matter, would such an interpretation prevent state agents from seizing garbage and turning it over for use in federal prosecutions.
IY.
[¶ 57.] In summary, to ensure that our constitutional jurisprudence develops in a methodical and authentic way, we must be guided by a set of interpretive principles. Authoritative and neutral analysis of South Dakota’s Constitution cannot advance from episodic and reactionary borrowing of results from other state courts. Litigants must demonstrate that the text, history, or purpose of a South Dakota constitutional provision supports a different interpretation from the corresponding federal provision. If there is any place where the principle of judicial restraint ought to deter us, it is in the area of constitutional divergence. As Professors Whitebread and Slobogin warn, “wide-open state [court] activism runs counter to judicial decisionmaking goals of clarity, efficiency, and principled reasoning.... [Such activism] is bad policy because it promotes uncertainty, questionable duplication of review, and result-oriented jurisprudence.” WHITEBREAD & SLOBOGIN, supra, § 34.03, at 1034 & § 34.04, at 1042. These words offer valid cautions, but, in the right ease, they should not discourage us from a vigorous analysis of South Dakota’s Constitution.
. See e.g., City of Mesquite v. Aladdin’s Castle, Inc., 455 U.S. 283, 292, 102 S.Ct. 1070, 1076, 71 L.Ed.2d 152 (1982); PruneYard Shopping Center v. Robins, 447 U.S. 74, 81, 100 S.Ct. 2035, 2040-41, 64 L.Ed.2d 741 (1980); Oregon v. Hass, 420 U.S. 714, 719, 95 S.Ct. 1215, 1219, 43 L.Ed.2d 570 (1975). Conversely, state supreme courts cannot interpret the United States Constitution to provide greater protections than United States Supreme Court's own constitutional precedent allows. Arkansas v. Sullivan, 532 U.S. 769, 772, 121 S.Ct 1876, 1878, 149 L.Ed.2d 994 (2001).
. "[S]tate constitutional law today is a vast wasteland of confusing, conflicting, and essentially unintelligible pronouncements. [T]he fundamental defect responsible for this state of affairs is the failure of state courts to develop a coherent discourse of state constitutional law[.]” James A. Gardner, The Failed Discourse of State Constitutionalism, 90 MICH L. REV. 761, 763-64 (1992).
. Of course, a similar quality analysis would be necessary in discussing a state constitutional provision with no federal counterpart.
. Cf. Sweeney v. Leapley, 487 N.W.2d 617, 620 (SD 1992) ("We feel that South Dakota should provide more protection than afforded [by the United States Supreme Court].)."
.Peter J. Galie, State Supreme Courts, Judicial Federalism and the Other Constitutions, 71 JUDICATURE 100 (1987) (referring to numerous articles on the "new judicial federalism”).
. Several other state courts rely on sets of criteria in analyzing their constitutions. See, e.g., State v. Gunwall, 106 Wash.2d 54, 720 P.2d 808, 812 (1986) (six factors); State v. Jewett, 146 Vt. 221, 500 A.2d 233, 237-38 (1985); State v. Hunt, 91 N.J. 338, 450 A.2d 952, 962-63 (1982) (Handler, J., concurring) (seven divergence criteria). To some degree, the divergence standards recommended in this writing were inspired by these decisions.
. With our shared heritage, our sister state, North Dakota, may also have decisions that could shed light on the background of our constitutional provisions. See Cardiff v. Bismarck Pub. Sch. Dist., 263 N.W.2d 105, 112-13 (N.D.1978) (comparing constitutions of North Dakota, South Dakota, Montana, and Washington, since all four states were admitted to the Union under the same Enabling Act).
. We have referred to the debates from these Conventions in other cases. See, e.g., Doe v. Nelson, 2004 SD 62, ¶ 11 n. 5, 680 N.W.2d 302, 306 n. 5; Pitts v. Larson, 2001 SD 151, ¶ 24 and n. 4, 638 N.W.2d 254, 260 and n. 4 (Gilbertson, C.J., dissenting); In re Certification of Question of Law, 2000 SD 97, ¶¶ 31-32, 615 N.W.2d 590, 600-01.
. See, e.g., State v. Allison, 2000 SD 21, ¶¶ 6-10, 607 N.W.2d 1, 2-5 (examination of history of imprisonment for debt in colonial and early state histories in the context of adoption of Article VI, § 15, of the South Dakota Constitution).
. In addition to Judge Corson, two other members of the original South Dakota Supreme Court were also delegates: Judge Alphonso Kellam was a delegate to the 1883, 1885, and 1889 Constitutional Conventions; Judge John E. Bennett was a delegate to the 1885 and 1889 Constitutional Conventions. See Ross H. Oviatt, South Dakota Justice— The Judges and the System 2-4 (1989).
. Gooder voluntarily adopted the rule that illegally seized evidence should be suppressed in accord with the federal rule. Gooder preceded by thirty years the decision in Mapp v. Ohio, 367 U.S. 643, 655, 81 S.Ct 1684, 1691, 6 L.Ed.2d 1081 (1961), in which the Supreme Court made the rule of exclusion in illegal search and seizures applicable to the states.
. United States v. Dudek, 530 F.2d 684, 689 (6thCir.1976), conviction aff'd on other grounds, 560 F.2d 1288 (6thCir.1977), cert. denied, 434 U.S. 1037, 98 S.Ct. 774, 54 L.Ed.2d 786 (1978) (violation of state law does not preclude admission in federal court — "no doubt that in a federal criminal prosecution federal standards are applied to determine the admissibility of evidence”).