Mixed Jurisdictions Compared: Private Law in Louisiana and Scotland

Author: Vernon V. Palmer; Elspeth Reid
Publisher: Edinburgh University Press
ISBN: 9781399571876
Published In: October 2026
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

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A comparative study of the 'mixed jurisdictions' of Scotland and Louisiana Returning to a theme featured in some of the earlier volumes in the Edinburgh Studies in Law series, this volume offers an in-depth study of ‘mixed jurisdictions’ – legal systems which combine elements of the Anglo-American Common Law and the European Civil Law traditions. This new collection of essays compares key areas of private law in Scotland and Louisiana. In 13 chapters, written by distinguished scholars on both sides of the Atlantic, it explores not only legal rules but also the reasons for the rules, discussing legal history, social and cultural factors, and the law in practice, in order to account for patterns of similarity and difference. Contributions are drawn from the Law Schools of Tulane University, Louisiana State University, Loyola University New Orleans, the American University Washington DC, and the Universities of Aberdeen, Strathclyde and Edinburgh.

List of Contributors

List of Abbreviations

Table of Cases

1. Praedial Servitudes, Kenneth G C Reid

2. Title Conditions in Restraint of Trade, John A Lovett

3. Servitudes: Extinction by Non-Use, Roderick R M Paisley

4. Inheritance and the Surviving Spouse, Ronald J Scalise Jr

5. Ownership of Trust Property in Scotland and Louisiana, James Chalmers

6. The Legal Regulation of Adult Domestic Relationships, Kenneth McK Norrie

7. Impediments to Marriage in Scotland and Louisiana: An Historical - Comparative Investigation, J-R Trahan

8. Contracts of Intellectual Gratification - A Louisiana-Scotland Creation, Vernon Valentine Palmer

9. The Effect of Unexpected Circumstances on Contracts in Scots and Louisiana Law, Laura Macgregor