International Choice of Law: A Proposal for a New Enclave of Federal Common Law

This Comment examines the need and authorization for federal common law of international choice of law in view of current conflicts law and theory. Part I reviews the types of conflicts laws in use today. Part II discusses federal common law as it has developed in the area of international relations and as it might apply to conflict of laws. Part III proposes the adoption of federal common law in international conflict of laws and also discusses the option of legislative implementation of the federal full faith and credit statute. A model is introduced for the proposed federal common law of international conflicts; Part IV reexamines the recent case of Kunstsammlungen zu Wemar v. Elicofon in light of the model