When is it necessary to certify a question to Michigan Supreme Court, when protected rights are infringed upon?

Question

The Court finds that the next of kin has a federally protected constitutional right to a deceased body for final disposition, grounded in the Fourteenth Amendment Due Process Clause. That right is clearly established. What is meant by "because this is a federal cause of action, it is not necessary to certify a question to the Michigan Supreme Court," (conduct causing constitutional right protected by infringement by State must be fairly attributable to the state?)

James L. Arrasmith · Answer

When a federal cause of action is involved, it typically means that the issue at hand is governed by federal law rather than state law. In this context, the court is addressing a constitutional right protected under federal law, specifically the Fourteenth Amendment's Due Process Clause. Since the federal court is interpreting and applying federal constitutional principles, there is no need to seek guidance from the Michigan Supreme Court on this matter. 
 
The concept of certifying a question to a state's supreme court arises when a federal court is uncertain about how state law should be applied or interpreted. However, in your case, since the issue revolves around a federal constitutional right, the federal court has the authority to decide the matter without deferring to state courts. 
 
The phrase "conduct causing constitutional right protected by infringement by State must be fairly attributable to the state" means that for a constitutional claim to be valid, the action infringing upon the right must be connected to state action. In your situation, the infringement of the next of kin's right to a deceased body for final disposition must involve some form of state involvement or responsibility.

Q: When is it necessary to certify a question to Michigan Supreme Court, when protected rights are infringed upon?