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Conflict of decision among the federal courts of appeals has produced a lack of uniformity in national law.' The "law of the circuit" rulethat the decision of one court of appeals is binding only within the circuit and need not be followed by district courts or courts of appeals outside the circuit-causes such conflict among the circuits. Although it has been thought that the Supreme Court would resolve intercircuit conflicts, the Court as a practical matter cannot hear and decide all cases containing an issue on which intercircuit conflict exists. 3 The Court's limitations in this respect have become increas-

Securing Uniformity in National Law: A Proposal for National Stare Decisis in the Courts of Appeals