This study provides a comparative assessment of the current state of Private International Law by exploring the fundamental philosophical, ideological, and methodological challenges encountered during the 20th century and the responses to those challenges in the western world. Among the questions discussed are: the dilemma between "conflicts justice" and "material justice"; the conflict between the goal of international uniformity and the need or desire to protect state or national interests; the tension between the goals of certainty and flexibility; the symbiosis of the multilateral, unilateral, and substantive methodologies; and the antagonism or co-existence between choice-of-law rules and flexible "approaches", and between "jurisdiction-selecting" and "content-oriented" rules or approaches. Providing insight and diverse perspectives from 19 countries, this book should be useful to teachers or students of private international law or comparative law.

This volume is an authoritative and complete yet compact presentation of private international law--or conflict of laws--in the United States of America. Its author is the world's leading expert on comparative conflicts law today. (M. Reimann, Comparative Law and Private International Law, in The Oxford Handbook of Comparative Law 1363 at 1380 (2006)). Having studied and taught law in both Europe and the United States, the author is uniquely qualified to identify and explain in language understandable to readers outside the U.S. the American peculiarities of the subject. His three-decades experience in writing on thousands of American judicial decisions is particularly valuable in understanding and presenting the practical essentials of the subject to practitioners and academics alike.American courts encounter, at a rate of more than two thousand per year, conflicts among the laws of the fifty U.S. states (interstate conflicts) and between state or federal laws and those of foreign countries (international conflicts), thus making American conflicts law one of the richest and most complex in the world. This volume explains the differences between the two categories and presents the established and emerging jurisprudence in a concise and clear manner, while also providing an enlightening discussion of the multifaceted role of U.S. federalism, which is essential to the foreign reader's understanding of American conflicts law.Dr Symeonides has done a great service in collecting and organizing this scattered material into a coherent but non-technical and readily usable whole that offers all interested lawyers an easy-to-use but authoritative overview of the subject. The discussion includes:the federal-state allocation of lawmaking and judicial powers; the constitutional limitations on state choice of law; the resolution of conflicts between federal and foreign law; recognition of sister-state and foreign-country judgments; judicial jurisdiction in interstate and international conflicts; recognition of sister-state and foreign-country judgments; the choice-of-law revolution and its aftermath; and choice of law in torts, products liability, contracts, status and domestic relations, property, marital property, successions, and statutes of limitation.

This book is an updated and expanded version of the General Course delivered by the author at the Hague Academy of International Law in 2002. The book chronicles and evaluates the intellectual movement known as "the revolution" in American private international law. This movement began in the 1960s, caught fire in the '70s, spread in the '80s and declared victory in the '90s, leading to the abandonment of the centuries-old choice-of-law system, at least for torts and contracts. This book: -explores the revolution's philosophical and methodological underpinnings; -provides the most comprehensive and systematic analysis of court decisions following the revolution; -identifies the revolution's successes and failures; and -proposes ways and means (including a new breed of "smart" choice-of-law rules) to turn the revolution's victory into success.