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The Hague Convention on Child Support and Other Forms of Family Maintenance: Divergent Private International Law Rules and the Limits of Harmonization

Published online by Cambridge University Press:  28 February 2017

Robert G. Spector
Robert G. Spector*
Affiliation:
University of Oklahoma Law Center
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Abstract

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Type
Divergence and Harmonization in Private International Law
Information
Proceedings of the ASIL Annual Meeting , Volume 101 , 2007 , pp. 353 - 356
Copyright
Copyright © American Society of International Law 2007

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References

1 436 U.S. 84 (1978).

2 436 U.S. at 98.

3 Council of the European Union, Regulation on Jurisdiction and the Recognition and Enforcement of Judgments in Civil and Commercial Matters, No.44/2001, Art. 5.2 (Dec. 22, 2000). The discussions at the special commissions indicated that, with the possible exception of Korea, the United States is the only country that does not accept the principle of allowing the creditor to sue at home.

4 See discussion in Spector, Robert G. Toward an Accommodation of Divergent Jurisdictional Standards for the Determination of Maintenance Obligations in Private International Law, 36 Fam. L.Q. 273 (2002)Google Scholar.

5 See Spector, supra note 4.