Consider this not-too-uncommon scenario. The trial court granted your motion for summary judgment and dismissed the complaint. The case is over, and your client is thrilled. Your adversary files an appeal. You urge the appellate panel to affirm on any or all of the independent grounds the trial court held were sufficient to grant summary judgment. The appellate division affirms the judgment but reaches only a single issue to do so. And so, while you would have liked the panel to affirm on several bases, you're nonetheless elated that your client's victory on summary judgment is secure. Then, 20 days later, much to your chagrin, you get your adversary's petition for certification to the Supreme Court of New Jersey.