A third approach is a variation on the second. Known as the “criteria” approach, it presumes that parallel state and federal constitutional provisions are identical in meaning. State courts following the criteria approach then will entertain a departure from that presumption and consider an independent interpretation of the state *847 provision only if certain specified criteria are satisfied.The rationale for this approach seems to be a concern that departures from federal constitutional law have the potential to appear willful and result-oriented and thus need to be specially justified