 The relatively streamlined process of sending a certified question to a state appellate court also relieves federal courts of the unwieldy procedure of "Pullman" abstention, under which Federal courts abstain from deciding on the constitutionality of state laws while litigation seeking the construction of those laws is pending in state courts.In 1967, a Uniform Act was first proposed to establish a standard procedure for certified questions.In "Lehman Bros. v. Schein", the Supreme Court praised the certified question procedure as helping to build a cooperative judicial federalism.