Professor Ronald A. Brand, who just over a year ago was caught slumming it here at Letters Blogatory, has published two new papers on SSRN that will be of interest to readers.
The first, Jurisdictional Developments and the New Hague Judgments Project, is a brief look at developments in the US and European approaches to the law of personal jurisdiction and their implications for the renewed discussions about recognition and enforcement of judgments in the Hague Conference.
The second, Implementing the 2005 Hague Convention: The EU Magnet and the US Centrifuge, looks comparatively at the recast of Brussels I in Europe and the fight over the right approach to implementation of the Choice of Court Agreement Convention in the US.1
Both are highly recommended!
- Just to editorialize on this very briefly, I’d say: yes, a federal approach modeled on the FAA would be best, but let’s not let the perfect be the enemy of the good. The Rube Goldberg of cooperative federalism is not ideal but will get the job done adequately.