Interest Analysis and Choice of Law- The Dubious Dominance of Domicile

The last thirty years have witnessed a fundamental change in the landscape of choice of law doctrine. The traditional learning, which previously dominated the approach of American courts to choice of law, was largely swept aside by a surge toward more modern approaches, particularly as exemplified by the groundbreaking work of Brainerd Currie. Currie and others opposed the traditional learning primarily because it was grounded in obsolete notions of "vested rights"" and had little relation to many of the real world considerations that should bear on choice of law decisions.