Way back in 1992, the United States asked the Hague Conference on Private International Law to draft a global treaty on jurisdiction and judgments, at the initiative of Harvard Law School’s Arthur von Mehren. The negotiators could never bridge the gap between the U.S. and European ideas of jurisdiction. They settled in 2005 on a simple treaty that would make court judgments easily enforceable worldwide except in rare cases such as those involving fraud or corruption. In other words, a New York Convention for court judgments.
That’s when the process flew apart. The American Law Institute drafted a federal implementing law similar to the Federal Arbitration Act. The Uniform Law Commission insisted that each state pass its own. Both the groups were founded near the turn of the 20th century to unify U.S. law. The difference is that the American Law Institute is dominated by academics. Members of the Uniform Law Commission are mostly appointed by the 50 state governors, and have a lot of pull in Congress.
