Open Access. Powered by Scholars. Published by Universities.®

Conflict of Laws Commons

Open Access. Powered by Scholars. Published by Universities.®

Articles 1 - 6 of 6

Full-Text Articles in Conflict of Laws

Whose Law Of Personal Jurisdiction? The Choice Of Law Problem In The Recognition Of Foreign Judgments, Tanya J. Monestier Oct 2016

Whose Law Of Personal Jurisdiction? The Choice Of Law Problem In The Recognition Of Foreign Judgments, Tanya J. Monestier

Journal Articles

It is black-letter law that in order to recognize and enforce a foreign judgment, the rendering court must have had personal jurisdiction over the defendant. While the principle is clear, it is an open question as to whose law governs the question of personal jurisdiction: that of the rendering court or that of the recognizing court. In other words, is the foreign court’s jurisdiction over the defendant governed by foreign law (the law of F1), domestic law (the law of F2), or some combination thereof? While courts have taken a number of different approaches, it seems that many courts regard …


Convention Providing A Uniform Law On The Form Of An International Will: Problems With State Probate Law, Jack N. Sibley Jun 2016

Convention Providing A Uniform Law On The Form Of An International Will: Problems With State Probate Law, Jack N. Sibley

Georgia Journal of International & Comparative Law

No abstract provided.


Foreign Investment Protection And Icsid Arbitration, Charles Vuylsteke Jun 2016

Foreign Investment Protection And Icsid Arbitration, Charles Vuylsteke

Georgia Journal of International & Comparative Law

No abstract provided.


From Baby M To Baby M(Anji): Regulating International Surrogacy Agreements, Yehezkel Margalit Jan 2016

From Baby M To Baby M(Anji): Regulating International Surrogacy Agreements, Yehezkel Margalit

Hezi Margalit

In 1985, when Kim Cotton became Britain’s first commercial surrogate mother, Europe was exposed to the issue of surrogacy for the first time on a large scale. Three years later, in 1988, the famous case of Baby M drew the attention of the American public to surrogacy as well. These two cases implicated fundamental ethical and legal issues regarding domestic surrogacy and triggered a fierce debate about motherhood, child-bearing, and the relationship between procreation, science and commerce. These two cases exemplified the debate regarding domestic surrogacy - a debate that has now been raging for decades. Contrary to the well-known …


Lack Of Marketability And Minority Discounts In Valuing Close Corporation Stock: Elusiveness And Judicial Synchrony In Pursuit Of Equitable Consensus, Stephen J. Leacock Jan 2016

Lack Of Marketability And Minority Discounts In Valuing Close Corporation Stock: Elusiveness And Judicial Synchrony In Pursuit Of Equitable Consensus, Stephen J. Leacock

Faculty Scholarship

No abstract provided.


A Battlefield Map For Nfl V. Insurance Industry Re: Concussion Liabilities, Christopher French Dec 2015

A Battlefield Map For Nfl V. Insurance Industry Re: Concussion Liabilities, Christopher French

Christopher C. French

When the superstar athlete -“Iron Mike” Webster - a 9-time National Football League (NFL) Pro Bowler, 4-time Super Bowl Champion, Hall of Fame center for the Pittsburgh Steelers died at age 50 with severe brain dysfunction after becoming homeless and living in a truck, it was discovered he had a previously nameless disease, Chronic Traumatic Encephalopathy (CTE). The discovery of CTE opened the floodgates on interest in delayed manifestation brain diseases caused by repeated blows to the head. As part of that flood, numerous class actions were brought by retired NFL football players against the NFL for their alleged …