In California by law (CIV § 1749.5CIV § 1749.5) any gift certificate with a cash value of less than ten dollars ($10) is redeemable in cash for its cash value. California has passed a new bill that increases this to $15 and also includes eGiftcards.
Read: List Of Websites To Cash Out Giftcards That Are Under $1-$10 (Varies By State)
Hat tip to reader RM