Codification of Conflicts Law

Codification of conflicts law, a reality in much of the world,' has been a matter somewhat remote from domestic American concern. Although some have noted and analyzed foreign developments from a comparative perspective, their interest has been largely in identifying the extent to which foreign drafting has reflected acceptance or rejection of American doctrines.2 Now, for the first time in living memory, an American state has begun a full-blown codification of its conflicts law. Louisiana, an heir to the civil law tradition,3 is the site of this event, and the reporters for this revision of the state's Civil Code are trained in continental methodology.4 How will these drafters, comfortable with a tradition of codification, yet intimately familiar with the trends and tensions of current American conflicts law, adopt or adapt the rules and approaches proffered by courts and scholars here and abroad? Fascinating first clues are provided by the first segment of the

Political science · Comparative and International Law Studies · Conflict of Laws and Jurisdiction · Judicial and Constitutional Studies · Law