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

Law Commons

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

Journal Articles

1998

Comparative and Foreign Law

Penn State Law

National law

Articles 1 - 1 of 1

Full-Text Articles in Law

Debating The Proper Role Of National Law Under The New York Convention, Thomas E. Carbonneau Jan 1998

Debating The Proper Role Of National Law Under The New York Convention, Thomas E. Carbonneau

Journal Articles

One of the many consequences of the progressive development of globalization apparently has been to incite a vigorous debate among leading members of the international arbitral community about the role of national law in implementing the enforcement regime of the New York Arbitration Convention (Convention). The debate was provoked by federal court rulings in two recent cases: Chromalloy Aeroservices v. Arab Republic of Egypt (Chromalloy) and Alghanim & Sons v. Toys"R" Us (Toys "R" Us). Prior to these opinions, there appeared to have been an implicit consensus in the international community regarding the "anational"character of …