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"In both February and May of this year, the U.S. Court of Appeals for the Second Circuit did something that it appears not to have done in an immigration case in more than fifteen years, and that is rare for other courts to do in such cases as well. In Nguyen v. Holder, on February 14, 2014, and Efstathiadis v. Holder, on May 20, 2014, the Second Circuit chose to certify questions of state law about which it was uncertain to the highest court of the relevant state – New York in Nguyen, and Connecticut in Efstathiadis -- rather than seeking to answer those questions itself. This is at least a notable coincidence given the historical rarity of such certification in immigration cases, and merits watching to see if it is the beginning of a broader trend." - David A. Isaacson, June 16, 2014.