Access the full text.
Sign up today, get DeepDyve free for 14 days.
References for this paper are not available at this time. We will be adding them shortly, thank you for your patience.
WILLIS L.M. REESE It is a human tendency to over-simplify. We are frequently tempted to subsume under some simple phrase or catchword mat ters that in reality are complex and diverse. So it is with American choice of law. Frequently it is said that this law is extremely flex ible and fluid, that it disregards almost entirely the values of pre dictability of decision and uniformity of resul t and that what results, in effect, is a system of ad hoc decision. Conclusions of this tenor can be based on the opinions of some American courts and on the writings of some American authors. Also, it is hardly surprising, in view of what Americans themselves have said, tha t this rather sim plistic view of American choice of law is the one that is generally held in Europe. The attempt will be made in this paper to demon strate that this view present s a distorted picture of th e situation that actually exists. The great majority of the recent choice-of-law cases in the United States have involved suits brought to recover for personal in juries. This is an area where there is little predictability of result even in
American Journal of Comparative Law – Oxford University Press
Published: Jan 1, 1982
Read and print from thousands of top scholarly journals.
Already have an account? Log in
Bookmark this article. You can see your Bookmarks on your DeepDyve Library.
To save an article, log in first, or sign up for a DeepDyve account if you don’t already have one.
Copy and paste the desired citation format or use the link below to download a file formatted for EndNote
Access the full text.
Sign up today, get DeepDyve free for 14 days.
All DeepDyve websites use cookies to improve your online experience. They were placed on your computer when you launched this website. You can change your cookie settings through your browser.