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In United States v. More (1805), the Court held that the ordinary means of appeal, the writ of error, could not be utilized in criminal cases from the circuit courts.[25] This contributed to the importance of the certificate of division in criminal cases. The Marshall Court (1801 1835) heard thirty one criminal cases arising from certificates of division; the Taney Court (1836 1864), fifteen; the Chase Court (1864 1873), seventeen; the Waite Court (1874 1888), thirty eight; and the Fuller Court (1888 1910), fourteen..
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