The Conflicts Book of the Louisiana Civil Code: Civilian, American, or Original?

Abstract:     
This article is a discussion of the Louisiana Conflicts Codification by its drafter. The article explains why and how this first and only comprehensive American conflicts codification: (1) combines the best elements from the vast laboratory of the American interstate conflicts experience, Louisiana's civil law heritage, and Europe's rich codification tradition, while also charting an independent new course; (2) compresses the lessons of the American choice-of-law revolution into succinct, civilian-style rules and combines them with a flexible American-style "approach;" and (3) provides more certainty than the conflicts laws of any other state of the United States and more flexibility than any European conflicts codification.

Number of Pages in PDF File: 36

Keywords: codification, conflict of laws, private international law, choice of law, comparative law, civil law

JEL Classification: K1, K10, K13, K33, K40

Accepted Paper Series