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Choice of Law in the American Courts in 2023

Conflict of Laws

The thirty-seventh annual survey on choice of law in the American courts is now available on SSRN. Choice of Law The Eighth Circuit applied Mexican law to a suit against General Motors over a car crash in Mexico, while an Ohio state court applied South African law to invalidate a marriage. In Bartlett v.

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Anti-enforcement injunction granted by the New Zealand court

Conflict of Laws

For litigants embroiled in cross-border litigation, the anti-suit injunction has become a staple in the conflict of laws arsenal of common law courts. Kea alleges that the US default judgment is based on fabricated claims intended to defraud Kea. Gault J considered that the case was “very unusual” (at [68]).

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