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Interjurisdictional Certification And Choice Of Law, John B. Corr, Ira P. Robbins

Vanderbilt Law Review

There is a story, probably apocryphal, that, at a 1970s conference discussing the great potential and even greater problems of some economically developing countries, a rather cynical American economist is supposed to have remarked that "Brazil is the country of the future-and always will be." Some commentators believe that much the same could be said about the certification process, but with greater accuracy. Certification has beguiled and to some extent disappointed two generations of legal scholars.' Intended to resolve problems that arise when a court of one jurisdiction must apply the law of another jurisdiction, certification is the process by …