On April 16, 2015, the Virginia Supreme Court exercised its power under the Virginia Constitution, and its own Rule 5:40(a), to answer two certified questions posed by the United States District Court for the Eastern District of Virginia. See Bailey v. Spangler, 2015 Va. LEXIS 52, Record No. 141702 (April 16, 2015). The U.S. District Cour...
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