Comparative Contract Law: A Transystemic Approach With an Emphasis on the Continental Law: Cases, Text and Materials (Carolina Academic Press Law Casebook)

This is a casebook with an emphasis on Continental law, in a comparative, American-style format, with many references to U.S. and U.K. law. It illustrates the treatment of the most important topics of contract law by the various civil-law jurisdictions.

Each chapter begins with an introductory exposition, comparing and contrasting the law of the various jurisdictions, with numerous examples. This is followed by cases drawn from France, Brazil, Lithuania, Quebec, Russia, and other jurisdictions, as well as some from the United States. Each chapter ends with a set of exercises. The book serves as a good introduction to the principles of European Contract Law, which is the first step taken by Europe towards a pan-European contracts code. It can be used to teach American law students about Continental law in a familiar, case-based, format. It can also be used for teaching comparative contract law to European law students in the Socratic method. A teacher's manual will be available.