“This paper deals with the problem of the recognition and execution of American punitive judgments before German courts. Punitive damages belong to one of the most controversial areas of tort law and are interesting for foreign lawyers because they are a special feature in the American law and are not employed in civil law systems. The issue of the recognition of punitive judgments in foreign law systems that are unfamiliar with the category of punitive damages is problematic and occurs with reasonable frequency in the international legal relations …”
Madeleine Tolani, US Punitive damages before German courts: A Comparative analysis with respect to the Ordre Public. Annual Survey of International and Comparative Law, Vol. XVI, 2011.
First posted 2011-09-17 07:51:25
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