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Conflict of laws in the United States is the field of procedural law dealing with choice of law rules when a legal action implicates the substantive laws of more than one jurisdiction and a court must determine which law is most appropriate to resolve the action. In the United States, the rules governing these matters have diverged from the ...
Conflict of laws (also called private international law) is the set of rules or laws a jurisdiction applies to a case, ... For example, in the United States, ...
The Conflict of Laws. Fourth Edition. Oxford University Press. 2011. Chapter 4. Page 203 et seq. J H C Morris. "Contracts" The Conflict of Laws. Second Edition. Stevens and Sons. 1980. Chapter 13. Page 209 et seq. Dicey. "Contracts: General Rules" and "Particular Contracts". A Digest of the Law of England with Reference to the Conflict of Laws ...
In law, dépeçage (from the French, meaning "dismemberment") is a concept within the field of conflict of laws whereby different issues within a single case are governed by the laws of different jurisdictions.
The choice of law rules for contracts are more complicated than the law affecting other obligations because they depend on the express or implied intentions of the parties and their personal circumstances. For example, questions as to whether a contract is valid may depend on the capacity of the parties to enter into a contract.
In contract law, the lex loci contractus is the Law Latin term meaning "law of the place where the contract is made". [1] [2] It refers (in the context of conflict of laws) to resolving contractual disputes among parties of differing jurisdictions by using the law of the jurisdiction in which the contract was created.
Capacity (law) Characterisation (law) Choice of law; Choice of law clause; Comity; Conflict of divorce laws; Conflict of nullity laws; Conflict of property laws; Conflict of succession laws; Conflict of tort laws; Conflict of contract laws; Convention on the Exercise of Liberal Professions of 1889; Convention on the Exercise of Liberal ...
The local law determines who can sue and be sued as parties to the action. The case law on this question is not very consistent. For example, the English court held in Banque Internationale de Commerce de Petrograd v Goukassow [1923] 2 KB 682 that a dead person cannot be a party to an action even though this was possible under the lex causae ...