Collected Courses of the Hague Academy of International Law
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Flexibility versus Predictability and Uniformity in Choice of Law Reflections on Current European and United States Conflicts Law (Volume 226)
(55,181 words)
Hay, Peter
Keywords: United States of America | Conflict of laws | Europe | Private international law |
Mots clefs: Etats-Unis d'Amérique | Droit interrégional | Droit international privé | Europe | ABSTRACT Peter Hay, Professor at the University of Illinois at Urbana-Champaign, emphasizes in the introduction to his course that a contradiction between the need for flexibility (to avoid an unfair decision) and the need for legal certainty cannot be resolved. It is the natural consequence of the difference between the development…