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A certificate of division, a procedure for appellate review created by § 6 of the Judiciary Act of 1802, authorized the Supreme Court of the United States to hear questions of law certified from the United States circuit courts if the United States district court judge and the Supreme Court justice riding circuit were divided on that question. Between 1802 and 1896, certificates of division were the source of jurisdiction for approximately half of the criminal cases heard by the Supreme Court.