Mixed Jurisdictions Compared
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Some earlier volumes in the Edinburgh Studies in Law series have featured in-depth studies of the so-called 'mixed jurisdictions' - legal systems which combine elements of the Anglo-American Common Law and the European Civil Law traditions. This new collection of essays returns to that theme by comparing key areas of private law in Scotland and Louisiana. In thirteen chapters, written by distinguished scholars on both sides of the Atlantic, it explores not only legal rules but also the reasons for the rules, discussing legal history, social and cultural factors, and the law in practice, in…mehr

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Produktbeschreibung
Some earlier volumes in the Edinburgh Studies in Law series have featured in-depth studies of the so-called 'mixed jurisdictions' - legal systems which combine elements of the Anglo-American Common Law and the European Civil Law traditions. This new collection of essays returns to that theme by comparing key areas of private law in Scotland and Louisiana. In thirteen chapters, written by distinguished scholars on both sides of the Atlantic, it explores not only legal rules but also the reasons for the rules, discussing legal history, social and cultural factors, and the law in practice, in order to account for patterns of similarity and difference. This title will be of interest to students of comparative law at senior undergraduate and postgraduate level, academics and researchers and also those who are interested in the mixed jurisdictions for the lessons they offer in the context of harmonisation of private law in Europe. Vernon Valentine Palmer is a professor of comparative law at the Tulane Law School. His research interests in comparative law include the study of mixed jurisdictions, tort law in Europe, the codification of civil law and the history of slavery. He received in 2006 at Tulane University the Provost's Award for academic excellence. He is the author of more than forty books and articles and is President of the World Society of Mixed Jurisdiction Jurists. Among these are Mixed Jurisdictions Worldwide, The Louisiana Civilian Experience and Pure Economic Loss in Europe (with Mauro Bussani). Elspeth Reid has published extensively on comparative private law and on Russian legal matters. Her publications include Personal Bar (with John Blackie), and the edited collections Edinburgh Essays on Russia and A Mixed Legal System in Transition (with David Carey Miller). A former Editor of the Edinburgh Law Review she is a member of the Editorial Boards of the Edinburgh Law Review and the Electronic Journal of Comparative Law. She is a qualified solicitor.
Autorenporträt
Vernon Valentine Palmer is Thomas Pickles Professor of Law, and Co-Director of the Eason-Weinmann Center of Comparative Law at Tulane University Law School. Elspeth Reid is Professor of Scottish Private Law at the University of Edinburgh. She has published extensively in Scotland and abroad on comparative private law themes, including in particular the law of delict/tort. She is the Series Editor of the Edinburgh Studies in Law monograph series.