Tag Archives: conflict of laws

Case of the Day: Shanghai Commercial Bank v. Chang

The case of the day is Shanghai Commercial Bank Ltd. v. Chang (Wash. Ct. App. 2016). The bank had a Hong Kong judgment against Chang on account of an unpaid debt. The bank sought recognition and enforcement of the Hong Kong judgment in Washington, where Chang and his wife, Chen, had lived for many years. They were married long before Chang incurred the debt to the bank, though Chen herself had not incurred the debt and didn’t know about it at the time. The trial court held previously held that the Hong Kong judgment was entitled to recognition, and in today’s case it held that the judgment could be enforced against the marital property of Chang and Chen (Washington is a community property state). Chang appealed.
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Kuwait Airways Shamefully Drops New York-London Route To Avoid Serving Israelis

Back in October, I reported that Kuwait Airways, which operates flights between New York and London, was refusing to sell tickets to customers with Israeli passports, citing Kuwaiti law, which forbids doing business with Israelis. After first ignoring the complaint of an Israeli traveler, Eldad Gatt, the Department of Transportation eventually did the right thing, determining that the airline’s policy violated US law, which prohibits unreasonable discrimination. Since then, the airline petitioned for review, but the Department rejected its petition and instructed the airline to cease and desist from further violations of the law.
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A Comparative Look At The New Hague Principles on Choice of Law & the Restatement (Second) of Conflict of Laws: Last Post

This is the third and last in a series of posts comparing the new Hague Principles on Choice of Law in International Commercial Contracts and the Restatement (Second) of Conflict of Laws. Before digging in, I want to give you the analysis of the two texts by my co-author, Jonathan Levin. His lengthy and detailed table was the genesis of the whole project, so I recommend it to you.
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