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The Return Of The Unprovided-For Case, Michael S. Green

Georgia Law Review

The unprovided-for case is a puzzle that arises under
governmental interest analysis, the predominant choice-of-

law approach in the United States. As its name suggests,
in the unprovided-for case the law of no jurisdiction seems
to apply. There is a gap in the law. After its discovery by
Brainerd Currie in the 1950s, the unprovided-for case
proved to be an embarrassment for interest analysts and a
focal point for critics.
In 1989, however, Larry Kramer published an argument
that the unprovided-for case is a myth. There is no gap in
the law. Kramer's argument has been well-received, so
much so …