Abstract
The selection of the law applicable to a certain relationship may seem to be the sole purpose of choice of law rules. However, it is questionable whether this choice should be made independent from the content of the various laws available. The selection of the most appropriate law cannot disregard the social, economic and political values that form the basis of substantive rules. In modern legal systems, social values such as consumer protection are recognized to a growing extent.
The present work explores the concept of choice of law – namely party autonomy with a focus on consumer contracts in the U.S. and the E.E.C. The present work compares choice of law conflicts in four U.S. states: Illinois, Georgia, California and New York with the 1980 E.E.C. Convention on the Law Applicable to Contractual Obligations. This thesis concludes that choice of law has an important function in preventing the evasion of a large part of consumer protective provisions.
Repository Citation
Henckaerts, Jean-Marie, "Choice of Law Clauses in Consumer Contracts: A Comparative Study of American and E.E.C. Law" (1990). LLM Theses and Essays. 307.
https://digitalcommons.law.uga.edu/stu_llm/307
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