John Coyle joined the faculty at the University of North Carolina School of Law in 2010 and serves as the Reef C. Ivey II Distinguished Professor of Law. His teaching and research interests include contracts, corporate law, and private international law.
Over the past several months, three state appellate courts in the United States have examined whether a “talaq” divorce obtained in another country is entitled to recognition as a matter of comity. In this post, I first survey the rules relating to the recognition of foreign divorce judgments in the United States. I then explain […]
The Uniform Child Custody Jurisdiction and Enforcement Act, which has been enacted by every U.S. state, discourages forum shopping in child custody disputes by assigning subject-matter jurisdiction to the court located in the “home state” of the child. In Allen v. Allen, decided on April 21, 2026, the Montana Supreme Court had to determine whether […]
The thirty-ninth annual survey on choice of law in the American courts is
It is common to see some variation of the phrase “without regard to conflict of laws principles” appear at the end of a choice-of-law clause. Here are some examples: “This Agreement shall be governed by and construed in accordance with the laws of the Republic of China, without regard to its principles concerning conflicts of […]
Can private actors utilize choice-of-law clauses selecting the laws of a foreign country to avoid laws enacted by the United States? In this post, I argue that the answer is a qualified yes. I first examine situations where the U.S. laws in question are not mandatory. I then consider scenarios where these laws are mandatory. […]
I have long argued – in
This post was written by Hannah Buxbaum, the John E. Schiller Chair in Legal Ethics and Professor of Law at the Indiana University Maurer School of Law in the United States. Last month, Judge Edward Davila, a federal judge sitting in the Northern District of California in the United States,
In every private international law system, the forum state reserves the right to reject the application of a foreign rule that deeply offends the forum’s fundamental sense of justice and fairness. In all systems, this “public policy reservation” (ordre public) operates as an exception to the forum’s choice-of-law rules, not its rules on jurisdiction or […]
A new paper by
The thirty-eighth annual survey on choice of law in the American courts is