Mixed Jurisdictions ComparedPrivate Law in Louisiana and Scotland

Abstract

Returning to a theme featured in some of the earlier volumes in the Edinburgh Studies in Law series, this volume offers an in-depth study of ‘mixed jurisdictions’ — legal systems that combine elements of the Anglo-American Common Law and the European Civil Law traditions. This book compares key areas of private law in Scotland and Louisiana. In thirteen chapters, written by 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. Contributions are drawn from the Law Schools of Tulane University, Louisiana State University, Loyola University New Orleans, the American University Washington DC, and the Universities of Aberdeen, Strathclyde, and Edinburgh.