John Coyle
University of North Carolina School of Law
John F. Coyle is the Reef C. Ivey II Distinguished Professor of Law at the University of North Carolina School of Law. He is a past chair of the AALS Section on Conflict of Laws and is currently an Adviser for the American Law Institute’s Restatement (Third) of Conflict of Laws. His articles on choice-of-law clauses, forum selection clauses, cross-border dispute resolution, and international commercial contracts have appeared in journals such as the Notre Dame Law Review, the William & Mary Law Review, the North Carolina Law Review, and the Iowa Law Review. Before entering the academy, he worked as a transactional attorney at Covington & Burling LLP.
Faux Forum Selection Clauses
In linguistics, a false friend (or faux ami) is a word from a different language that looks and sounds like a familiar word in English but, in fact, has a very different meaning. A classic example is the word “gift.” In English, the word means “present.” In German, the word means “poison.” These are not…
Continue ReadingChoice of Law in the American Courts in 2023
The thirty-seventh annual survey on choice of law in the American courts is now available on SSRN. The survey covers significant cases decided in 2023 on choice of law, party autonomy, extraterritoriality, international human rights, foreign sovereign immunity, adjudicative jurisdiction, and the recognition and enforcement of foreign judgments. So, on this leap day, we thought…
Continue ReadingAn Answer to the Billion-Dollar Choice-of-Law Question
On February 20, 2024, the New York Court of Appeals handed down its opinion in Petróleos de Venezuela S.A. v. MUFG Union Bank, N.A. The issue presented—which I described in a previous post as the billion-dollar choice-of-law question—was whether a court sitting in New York should apply the law of New York or the law…
Continue Reading