Conflict of Laws

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Section on Conflict of Laws
Columbia 2, North Tower/Lobby Level, San Diego Marriott Hotel & Marina

Choice of Law Reforms in the EU: A Model for the U.S. or a Cautionary Tale? Reflections by Scholars and Suggestions for Teachers

In January, 2009, the EU Regulation on the Law Applicable to Non-Contractual Obligations, known as Rome II, will go into effect. The Regulation will preempt national choice of law rules and apply to torts occurring both inside and outside the EU and has been characterized as “the European conflicts revolution.” The EU is also in the process of creating a Regulation on choice of law in contracts. The panel will explore these EU Regulations from both a European and American perspective. It will reflect on the practical, political and theoretical choices made by the drafters of the Regulations and will consider whether these Regulations provide models for changes in U.S. choice of law. The panel will also suggest ways that teachers can integrate choice of law developments outside the U.S. into a standard conflict of laws course.

Business Meeting at Program Conclusion.