Abstract

http://ssrn.com/abstract=2233928
 


 



Contract Law in Europe and the United States: Legal Unification in the Civil Law and the Common Law


Hein D. Koetz


Max Planck Institute for Comparative and International Private Law

March 15, 2013

Tulane European and Civil Law Forum (Tul. Eur. & Civ. L.F.), Vol. 27, pp. 1-16, 2012
Max Planck Private Law Research Paper No. 13/13

Abstract:     
Common law jurisdictions seem to accept internal legal diversity with a fair amount of equanimity. Although the United States, the United Kingdom and Canada are functioning single markets, they have no uniform contract or tort law nor do they seem to think that uniformity in these areas is meritorious or desirable as such. On the other hand civil law jurisdictions in general and the European Union in particular consider the harmonization and unification of contract law as a matter of great importance despite the fact that there is little evidence showing that uniformity is required by the practical requirements of a functioning economic community. The article discusses the development of the "Europeanization" of private law and speculates on the reasons which may have led European countries to devote much energy to the formulation, if not codification, of uniform rules of European contract law.

This article is published in this Research Paper Series with the kind permission of the Tulane European and Civil Law Forum in accordance with its Author/Journal Publication Agreement and Copyright License. For further information on the Journal, please visit its website.

Number of Pages in PDF File: 17

Keywords: Contract Law, Legal Unification in the Common Law and the Civil Law, Unification of European Contract Law

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Date posted: April 14, 2013  

Suggested Citation

Koetz, Hein D., Contract Law in Europe and the United States: Legal Unification in the Civil Law and the Common Law (March 15, 2013). Tulane European and Civil Law Forum (Tul. Eur. & Civ. L.F.), Vol. 27, pp. 1-16, 2012; Max Planck Private Law Research Paper No. 13/13. Available at SSRN: http://ssrn.com/abstract=2233928

Contact Information

Hein D. Koetz (Contact Author)
Max Planck Institute for Comparative and International Private Law ( email )
Mittelweg 187
Hamburg, D-20148
Germany
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