Renvoi and Depecage
Learn how courts decide which jurisdiction's choice-of-law approach to apply, along with how one jurisdiction’s law won't necessarily govern all aspects of a case.
Welcome to Renvoi and Dépeçage! In this lesson, we’ll start by examining renvoi, which implicates how courts decide which jurisdiction’s choice-of-law rules to apply. Then, we’ll talk about dépeçage, under which courts may apply different jurisdictions’ laws to discrete aspects of a case or claim.
First up, renvoi. In choice of law, grasping renvoi requires understanding two things. The first is that choice-of-law rules differ from state to state, just like substantive rules of decision and...