Conflict of Laws Conventions and Their Reception in National Legal Systems: Report for the United States
THE IMPACT OF UNIFORM LAW ON NATIONAL LAW: LIMITS AND POSSIBILITIES, J. Sanchez Cordero, ed., 2010
24 Pages Posted: 23 Jan 2011
Date Written: January 21, 2011
This is the U.S. national report on "Conflict of Laws Conventions and Their Reception in National Legal Systems," prepared for the Intermediate Congress of the International Academy of Comparative Law held in 2008. The report discusses the various mechanisms for implementation of conflict-of-laws conventions in the United States: through federal legislation, federal rulemaking and state legislation. It reviews the conflict-of-laws conventions to which the United States is party (including in the areas of family law and litigation procedure), as well as recent case-law under those conventions. It also examines relevant aspects of U.S. law on treaties, discussing the issue of self-executing versus non-self executing treaties within the particular context of private law conventions.
Keywords: Treaties, private international law, conflict of laws, choice of law, uniform laws, Hague Abduction Convention, Hague Intercountry Adoption Convention
JEL Classification: K33, K41
Suggested Citation: Suggested Citation