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| Acknowledgments | |
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| Introduction | |
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| Coice of Law | |
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| The Traditional Approach | |
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| Introduction | |
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| Traditional Theory: Jurisdiction-Selecting Rules | |
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| Torts | |
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| Contracts | |
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| Other Traditional Rules | |
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| Property | |
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| Marriage | |
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| Corporations | |
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| Traditional Practice: Escape Devices | |
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| Characterization | |
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| Substance vs. Procedure | |
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| Limitations Periods | |
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| Renvoi | |
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| Public Policy, Penal and Tax Laws | |
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| Public Policy | |
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| Penal and Tax Laws | |
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| The Traditional Flowchart; Pleading and Proving Foreign Law | |
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| Evaluation | |
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| Modern Approaches I (Interest Analysis) | |
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| Introduction | |
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| Statutory Solutions | |
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| Party Autonomy | |
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| Interest Analysis | |
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| Introduction: Critics of the First Restatement | |
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| Brainerd Currie | |
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| False Conflicts | |
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| Tooker v. Lopez | |
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| Schultz v. Boy Scouts of America, Inc | |
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| The Unprovided-For Case | |
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| True Conflicts | |
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| Moderate and Restrained Interpretation | |
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| Territorial Tiebreakers | |
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| Balancing and Comparative Impairment | |
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| Principles of Preference | |
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| Kramer's Canons | |
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| Others | |
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| Evaluation | |
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| Modern Approaches H (The Second Restatement and Better Law) | |
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| The Second Restatement | |
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| Torts | |
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| Contracts | |
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| Property | |
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| Evaluation | |
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| Better Law | |
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| The Approach | |
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| Evaluation | |
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| Pervasive problems | |
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| Depecage | |
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| Renvoi | |
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| Complex Litigation | |
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| Characterization | |
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| Constitutional Constraints on Choice of Law | |
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| Relevant Constitutional Provisions | |
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| Due Process | |
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| Privileges and Immunities | |
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| Full Faith and Credit | |
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| Others | |
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| Limits on the Use of Local Law as a Rule of Decision | |
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| Original Understandings | |
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| Evolution | |
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| Full Faith and Credit | |
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| Due Process | |
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| Privileges and Immunities | |
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| The Modern Synthesis | |
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| Summary and Evaluation | |
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| Rethinking Constitutional Choice of Law | |
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| Privileges and Immunities | |
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| Full Faith and Credit | |
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| Conclusion | |
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| The Obligation to Provide a Forum | |
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| Other Applications | |
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| Federal-State Conflicts | |
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| The Erie Doctrine | |
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| Klaxon | |
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| Federal Common Law | |
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| Rights and Obligations of the Federal Government | |
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| Other Federal Interests | |
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| Lack of State Power | |
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| Congressional Authorization | |
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| The Content of Federal Common Law | |
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| Preemption and Supremacy | |
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| Preemption | |
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| Federal Law in State Courts | |
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| Judicial Jurisdiction | |
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| Territoriality | |
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| Evolution of Specific Jurisdiction | |
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| General Jurisdiction | |
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| Attachment Jurisdiction | |
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| Transient Jurisdiction | |
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| Internet Jurisdiction | |
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| Declining Jurisdiction: Forum non conveniens | |
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| Recognition of Judgments | |
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| Introduction | |
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| Error, Public Policy, and Forum Interests | |
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| Limits on Full Faith and Credit | |
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| Procedural Rules, Limits on F-2 Jurisdiction | |
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| Limits on F-l Jurisdiction | |
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| Invalidity of F-l Judgment | |
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| F-l Judgment not on Merits | |
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| Lack of Finality in F-l | |
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| Equitable Decrees | |
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| Diversity Judgments | |
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| Family Law | |
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| Introduction | |
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| Marriage | |
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| Divorce | |
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| Ex Parte Divorce | |
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| Bilateral Divorce | |
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| Same-Sex Divorce | |
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| Child Custody and Adoption | |
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| Custody | |
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| Adoption | |
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| International Conflicts | |
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| Introduction | |
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| Extraterritorial Application of Federal Statutes | |
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| Extraterritorial application of the Constitution | |
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| Global Due Process | |
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| Other Possibilities | |
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| Textualism | |
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| Territoriality | |
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| Social Contract | |
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| Limited Government | |
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| Mutuality of Obligation | |
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| Choice of Law (Interest Analysis) | |
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| Cases | |
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| Recognition of Foreign Country Judgments | |
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| Table of Cases | |
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| Index | |