Some countries have multiple "supreme courts" whose respective jurisdictions have different geographical extents, or which are restricted to particular areas of law. In particular, countries with a federal system of government typically[citation needed] have both a federal supreme court (such as the Supreme Court of the United States), and supreme courts for each member state (such as the Supreme Court of Nevada), with the former having jurisdiction over the latter only to the extent that the federal constitution extends federal law over state law. Jurisdictions with a civil law system often have a hierarchy of administrative courts separate from the ordinary courts, headed by a supreme administrative court as it the case in the Netherlands. A number of jurisdictions also maintain a separate constitutional court (first developed in the Czechoslovak Constitution of 1920), such as Austria, France, Germany, Luxemburg, Portugal, Spain and South Africa.

Countries with more than one supreme court may divide their primacy by what factors?