European Conflicts Law After the American “Revolution”—Comparative Notes

This symposium looks at American Conflicts Law fifty years after Brainerd Currie’s death and asks, “where is it going?” This Article examines whether the American “revolution” has impacted Europeanconflicts law or whether the European developments, conversely, hold lessons for American law. In particular, the role of renvoi and dépeçage illustrate areas of departure between the two systems and shed light on where American conflicts law is—and should—be going.

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