Due to a dearth of recent Canadian conflict of laws decisions, I find myself paying more and more attention to U.S. cases, especially the differences between the U.S. and Canadian approaches to this subject. Having only yesterday discussed the difference in approaches to forum non conveniens, the decision of the U.S. Supreme Court in Medellín v. Texas (NYT article here), released today, provided me with a chance to consider a diametrically opposed path taken by the two legal systems with respect to domestic enforceability of international law.
Advertisements
