H No. v. t. e. The Constitution of the United States is the supreme law of the United States of America. (L 351) 1 (governing lis pendens and related actions); see also George A. Bermann, Parallel Litigation: Is Convergence Possible?, 13 Y.B. . . Court for S. Dist. ('CCI') in the case XYZ (confidential) v. Vifor International. on the Judiciary, Define Jurisdiction of U.S. Courts in Suits Against Foreign States, S. Rep. No. Close. 2004) (noting decision whether to grant antisuit injunction must take account of considerations of international comity); Karaha Bodas Co. v. Perusahaan Pertambangan Minyak Dan Gas Bumi Negara, 335 F.3d 357, 366 (5th Cir. 84 Thus, in personal injury suits, the local law of the state where the injury occurred generally applies, Close, As for foreign state immunity, the FSIA was passed in 1976 with the express purpose of shifting immunity determinations from the executive branch to the courts. Close. Close v. Century Intl Arms, Inc., 466 F.3d 88, 95 (2d Cir. See id. But the courts are free to draw for themselves its legal consequences in litigations pending before them. . Id. to extend comity, or is it simply a question of convenience? and, conversely, has used comity to explain why foreign governments should be allowed to bring suit as plaintiffs in American courts. 388 On the other hand, one should be skeptical of doctrines that allow the executive branch to dictate the outcomes of particular cases on foreign policy grounds. It is also possible for international law to shrink and leave gaps for comity to fill. The law of nations at the time was said to consist of four categories: (1) the necessary; (2) the voluntary; (3) the customary; and (4) the conventional. 141), Service incentive leave; conversion to cash, G.R. 183 Close 246 Close, During the nineteenth century, American courts invoked comity repeatedly as the basis for enforcing foreign lawsfrom those governing contracts, 109 Close, 1. towards greater consideration of private interests. endstream If it does it, it is as a matter of comity, and not as a matter of international right. Close Defects in the Information = jurisdictional infirmity, Wife wants annulment because of lazy gamer husband, G.R. The banks within the City of Manila objected for the various reasons given below. 316 See Flomo v. Firestone Nat. See, e.g., Mannington Mills, Inc. v. Congoleum Corp., 595 F.2d 1287, 129798 (3d Cir. 41 0 obj A state courts recognition of a foreign judgment did not raise a federal question. . Restatement (Second) of Conflicts of Laws 90 (No action will be entertained on a foreign cause of action the enforcement of which is contrary to the strong public policy of the forum.). Guar. 11 250 360 Walden v. Fiore, 134 S. Ct. 1115, 1122 (2014). No rule of customary international law requires the recognition of foreign law, Having focused in Part II on how the principle of international comity is incorporated in U.S. domestic law, this Article now turns in Part III to consider comitys relationship with international law. 162 2012). 281 This discretionary aspect of international comity has been responsible for much of the criticism that the doctrine has attracted over the years. Close 48 101, 102 (1993) (proposing single omnibus comity inquiry conducted as early as possible in the litigation process). 268 60 1996) (observing doctrines of act of state, foreign sovereign compulsion, and international comity. Close, On the restraint side of the ledger, some courts applying section 403 of the Restatement (Third) of Foreign Relations Law have determined the geographic scope of U.S. statutes on a case-by-case basis. H As Part III of this Article explains, however, international comity is distinct from international law. Some responsibility for the terminological confusion must be laid at Justice Scalias door. ([T]he doctrine of immunity for foreign sovereigns[] has its roots, not in the Constitution, but in the notion of comity between independent sovereigns.); see also Republic of Argentina v. NML Capital, Ltd., 134 S. Ct. 2250, 2255 (2014) (Foreign sovereign immunity is and always has been, a matter of grace and comity . 1985) (Acts of foreign governments purporting to have extraterritorial effect. . For a discussion of the relationship between customary international law and comity with respect to immunity today, see infra notes 300301 and accompanying text. The Supreme Court in Hilton v. Guyot (1895) famously defined international comity as "the recognition which one nation allows within its territory to the legislative, executive or judicial acts of another nation." That definition is incomplete, however, as comity encompasses much more than the recognition of foreign acts. 292 371 Sovereign party comity is deference to foreign government actors as litigants in U.S. courts. 2012) (Chapter 15 provides courts with broad, flexible rules to fashion relief appropriate for effectuating its objectives in accordance with comity.); Cunard S.S. Co. v. Salen Reefer Servs. and the President. endobj As a form of deference to a foreign tribunal, adjudicative comity under 1782 operates as a principle of recognition, although quashing discovery when it would interfere with foreign proceedings also combines an element of restraint. See Guar. 1605A. 29 Intl Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). <>stream 415 1987)); see also E. & J. Gallo Winery v. Andina Licores S.A., 446 F.3d 984, 989 (9th Cir. Choong Yong, 837 F.2d 33, 37 (2d Cir. 267 12112(c)(1) (incorporating defense similar to that in Title VII). Co. v. Tompkins, 304 U.S. 64 (1938). See Murray v. The Schooner Charming Betsy, 6 U.S. (2 Cranch) 64, 118 (1804) ([A]n act of Congress ought never to be construed to violate the law of nations if any other possible construction remains. Close To be sure, the Supreme Courts decision in Morrison makes clear that the presumption does not turn mechanically on the location of the conduct but rather requires a court to determine the focus of congressional concern. If so, the court will weigh the private and public interests Close In Pfizer, Inc. v. Government of India, the Court stated more broadly that it is within the exclusive power of the Executive Branch to determine which nations are entitled to sue, but in context the Court appears to have been referring to the Presidents recognition power and not any broader authority to deny recognized foreign governments access to U.S. courts. xs Id. endstream 1994). On almost identical facts, however, the Third Circuit rejected abstention. As the Second Circuit has observed, principles of comity counsel that injunctions restraining foreign litigation be used sparingly and granted only with care and great restraint. 70 (The district court did not abuse its discretion when it considered whether exhaustion was required under the controlling plurality opinion of this court.), vacated on other grounds, 133 S. Ct. 1995 (2013); Paramedics Electromedicina Comercial, Ltda. 240 2. subject matter of the tax 6. place of exercise, business or occupation being taxed. endobj but they come down firmly on the side of case-specific deference to the executive branch. Close See, e.g., Allied Bank Intl v. Banco Credito Agricola de Cartago, 757 F.2d 516, 522 (2d Cir. The Schooner Exchange, 11 U.S. (7 Cranch) at 136. 191 . With respect to the second myth, it is important to recognize that the proper role of the Executive depends on the comity doctrine at issue. But each fits this Articles definitiondeference to foreign government actors that is not required by international law but is incorporated in domestic lawand Part II defends the inclusion of each. But in fact, the separation-of-powers rationale for the act of state doctrine has international comity at its heart, for it rests on the perceived need for respect to foreign governments. International laws move away from strict territorial sovereignty in the early twentieth century strongly influenced the evolution of international comity in American courts. Co. v. California, 509 U.S. 764, 817 (1993) (Scalia, J., dissenting) (citing Story, supra note 54, 38, at 42). But as a general matter, the President does not haveand should not be givenauthority to dispose of particular cases on foreign relations grounds. When a court construes a federal statute to avoid conflict with international law under the Charming Betsy canon, it does not defer to a foreign government actor but rather to another body of law with a complex relationship to U.S. domestic law. (invoking unique genius of our Constitution in establishing two orders of government). And while W.S. xs 242 163 Close, Marshalls treatment of foreign sovereign immunity bears a striking resemblance to Huber and Storys descriptions of comity. See Story, supra note 54, 38, at 42 (In the silence of any positive rule,. The doctrine provides that American courts will not question the validity of a foreign act of state fully performed within the states own territory. H Close, In other areas, there is no international law core, and the rules mediating the relationship of the U.S. legal system with other countries are entirely rules of international comity. 205 . See infra notes 382385 and accompanying text (discussing deference to executive branch determinations of immunity). But customary international law requires the exhaustion of local remedies in domestic courts only before a claim is brought in an international tribunal. See 509 U.S. 764, 799 (1993) (concluding if defendants could comply with both U.S. and foreign law, there was no need to address other considerations that might inform a decision to refrain from the exercise of jurisdiction on grounds of international comity). Childress, supra note 20, at 51. Hilton, 159 U.S. at 16364. Leather Co., 246 U.S. 297, 303 (1918) (holding recognition is retroactive in effect and validates all the actions and conduct of the government so recognized from the commencement of its existence). 189 Finally, Part IV challenges two of the leading comity myths: (1) that comity must be governed by standards rather than rules; and (2) that comity determinations are best left to the executive branch. w3TPI2T0 BC#=3\. Close An educational institution operated by a religious organization was being required by a local government to pay real property tax. L. 601, 62478 (2006) (discussing principles of adjudicatory comity); Childress, supra note 20, at 63 (limiting analysis to one species of comity, adjudicatory comity); Anne-Marie Slaughter, A Global Community of Courts, 44 Harv. 317 356 375 Although Chief Justice Marshall did not use the word comity, Justice Story, who joined the opinion in The Schooner Exchange, would write just a decade later that the doctrine expounded in that case stands upon principles of public comity and convenience. and alternatively to decide whether to enjoin the parties from continuing such proceedings. 246 U.S. 297, 30304 (1918). . endstream With a proper definition of international comity and an understanding of the full range of American doctrines manifesting that principle, this Article now turns to examine critically some of the conventional wisdom. endobj 387 The recognition of foreign governments is controlled by the executive branch. Close Statement 2: International comity is an inherent limitation in taxation. International law binds the United States on the international plane, 14mc00190 (JSR), 2014 WL 3893953, at *1 (S.D.N.Y. 101 passing on the validity of foreign acts of state may hinder rather than further this countrys pursuit of goals. See 11 U.S. (7 Cranch) 116, 147 (1812) (Marshall, C.J.) Kirkpatrick & Co. v. Envtl. Sabbatino, 376 U.S. at 423. 136 364 This tax is imposed both to buyer and seller, respectively, 2% and 2%. Although the Third Restatement took the position that such interest balancing was required by customary international law, a (Am. See also infra Part III (discussing extent to which doctrines of foreign state immunity and foreign official immunity also reflect international law). 75 Is there an international duty See, e.g., Piper Aircraft Co. v. Reyno, 454 U.S. 235, 257 (1981) (The forum non conveniens determination is committed to the sound discretion of the trial court. and so Justice Holmes adopted a territorial approach using comity instead: For another jurisdiction, if it should happen to lay hold of the actor, to treat him according to its own notions rather than those of the place where he did the acts, not only would be unjust, but would be an interference with the authority of another sovereign, contrary to the comity of nations, which the other state concerned justly might resent. The power of taxation in the Philippines Constitution are grants of power and no limitations on taxing power. Corp. v. M.V. 959) (Washington, J. is compromised by case-by-case, selective determinations of jurisdiction by the Executive. .). 28 U.S.C. the act of state doctrine, xS**T0T0 Bih]" g Kirkpatrick & Co. v. Envtl. Public interests began to play a larger role around the turn of the twentieth century. Jan. 1, 1982. 303 259 330 172 See, e.g., F. Hoffmann-La Roche Ltd. v. Empagran S.A., 542 U.S. 155, 164 (2004) (relying on prescriptive comity to interpret geographic scope of Sherman Act in light of FTAIA). 1. nature, kind or classification of the tax 5. sources of income. 142 See id. Close, It is worth noting that the boundaries between international law and international comity may shift over time. (Collector v. Goodrich International (b) In case of property held in trust . 16 47252. 159 232 172), G.R. 208 Comity "counsels voluntary forbearance when a sovereign which has a legitimate claim to jurisdiction concludes that a second sovereign also has a legitimate claim to jurisdiction under principles of international law." Wharf, 210 F.3d at 1236 (quotations omitted). 30, at 36. See supra notes 379380 and accompanying text (discussing Chevron). Close, This definition of comity is both incomplete and ambiguous. See infra notes 352353 and accompanying text (discussing doctrines of adjudicative comity that operate as principles of restraint). Nature of Taxation Power? But the Ninth Circuit in Mujica, applying its newly minted doctrine of international comity abstention, endstream It has been fertile in suggesting a discretion unregulated by general principles. The second "is referred to as ' comity among courts' or adjudicatory comity, which 'may be viewed as a discretionary act of deference by a national court to decline to exercise jurisdiction in a case properly adjudicated in a foreign state.'" Id. (rejecting Securities and Exchange Commissions (SEC) argument that district court misapplied doctrine). Public interests found expression only as a justification for not extending comity to foreign laws, because under Hubers third maxim, one nation would enforce the laws of another only insofar as they do not cause prejudice to the power or rights of such government or of its subjects. .); GDG Acquisitions, LLC v. Govt of Belize, 749 F.3d 1024, 1030 (11th Cir. See Restatement (Third) of the Foreign Relations Law of the United States 441 (restating doctrine of foreign state compulsion); see also Anthony J. Colangelo, Absolute Conflicts of Law, 91 Ind. S Close But courts often restrain the geographic scope of U.S. law beyond what international law requires by applying a presumption against extraterritorialitya canon of interpretation based in part on international comity and not required by international law. 58 0 obj Banco Nacional de Cuba v. Sabbatino, 376 U.S. 398, 40809 (1964); see also The Sapphire, 78 U.S. (11 Wall.) 322 Later cases have emphasized separation of powers as the basis for the act of state doctrine. But once comity came to be seen exclusively in terms of deference to the paramount interests of another sovereign, endobj 1971) (rejecting reciprocity requirement for conflict of laws). . Abelesz v. Magyar Nemzeti Bank, 692 F.3d 661, 684 (7th Cir. 3. endobj endstream which requires a showing of exceptional circumstances after consideration of several factors. Close Close G.R. would be better served if these questions of law and fact were decided by the courts rather than by the executive branch. 81 Close 2008-01-15T10:41Z 1827) (Porter, J.)) See Landis v. N. Am. Tariff and Customs Code as of its amendment by PD 34. Such authority not only compromises judicial independence but also harms U.S. foreign relations by putting the Executive in the uncomfortable position of having to make decisions that may displease foreign governments. For another excellent discussion of deference to the Executive in foreign affairs, see Curtis A. Bradley, Chevron Deference and Foreign Affairs, 86 Va. L. Rev. Chimne I. Keitner, The Common Law of Foreign Official Immunity, 14 Green Bag 2d 61, 6364 (2010) (discussing head of state immunity as status-based immunity). 1782(a) (2012) (providing district court may order a person to provide evidence to foreign or international tribunals). In Wharf, we said the turnover order did not raise international comity concerns. Spector v. Norwegian Cruise Line Ltd., 545 U.S. 119, 130 (2005) (plurality opinion) (Kennedy, J.). was scornful of comity being used as a basis for taking decisions, and English private international law has never really gotten over it. Briggs, supra note 37, at 149; see also Collins, supra note 20, at 9194 (recounting criticism of comity in England). Id. x+ | 115(1)(b) (That a rule of international law or a provision of an international agreement is superseded as domestic law does not relieve the United States of its international obligation or of the consequences of a violation of that obligation.). See, e.g., Van Reimsdyk v. Kane, 28 F. Cas. See supra note 152 and accompanying text (explaining restraint was difficult to justify on basis of convenience). x+ | 2008) (Since Palestine is not recognized, under United States law, as a foreign state, the defendants cannot derivatively secure sovereign immunity as agencies and/or instrumentalities of Palestine.); Knox v. Palestine Liberation Org., 306 F. Supp. Ironically, international comity doctrines that promise deference to the Executive put the Executive in the uncomfortable position of having to make decisions that may disappoint foreign governments. 105 Close 401 There is also nothing inappropriate about having doctrines of status-based foreign official immunitylike diplomatic immunity and head-of-state immunityturn on the Presidents recognition of a foreign officials status. 18 Rep. 6, 27 (Mar. 393 130 Close Close 39 Its claim, then, can only be one of sovereign party comity. 1971) (articulating standard for torts); id. Modern customary international law requires sovereign immunity in some cases, although the exact contours of the customary international law rules are uncertain. The Schooner Exchange is sometimes read as applying international law, but Marshall treated the international rules governing immunity as defeasible by the United States. 61 Belg. See infra notes 386388, 404410 and accompanying text (discussing FSIA). American courts generally apply the same choice-of-law rules in interstate and international cases. See Curtis A. Bradley & Mitu Gulati, Withdrawing from International Custom, 120 Yale L.J. In the past, it would have answered that question by relying on rules of international law. 334 541 U.S. 677, 70102 (2004). <>stream but domestic law is free to go beyond these minimum requirements and extend greater immunity as a matter of comity. In summary, adjudicative comity operates in American law through limits on personal jurisdiction as well as doctrines like forum non conveniens (and others of more doubtful status) that allow courts to dismiss cases over which they have jurisdiction. 393 158 11, 51 (2010); see also Lawrence Collins, Comity in Modern Private International Law, in Reform and Development of Private International Law 89, 110 (James Fawcett ed., 2002) (The vast amount of material [on comity] cries out for some synthesis. 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