In People v. Teresinski (1982) 30 Cal.3d 822, the court explained that decisions of the United States Supreme Court "are entitled to respectful consideration citations and ought to be followed unless persuasive reasons are presented for taking a different course." (Teresinski, supra, 30 Cal.3d at p. 836.) These potentially persuasive reasons fall into four categories: (1) something in the language or history of the California provision suggests that the issue should be resolved differently than under the federal Constitution; (2) the high court opinion limits rights established by earlier precedent in a manner inconsistent with the spirit of the earlier opinion; (3) there are vigorous dissenting opinions or incisive academic criticism of the high court opinion; and (4) following the federal rule would overturn established California doctrine affording greater rights. (30 Cal.3d at pp. 836-837.)