Hartford Fire Insurance v. California – SCOTUS – 1993 (368-72) London reinsurers only offered insurance to US insurers if they changed their forms accordingly. Does US antitrust law govern British reinsurers giving reinsurance in London relating to US insurers?
Parliament has created COMPREHENSIVE regulatory regime over reinsurers
SOUTER Majority – clearly has jurisdiction.
Question is now – conflict of domestic law/foreign law which counsel restraining from exercising jurisdiction because of comity
Only thing that matters is London reinsurers aren’t REQUIRED by British law to do anything against American law.
Professor Damm – argues that four ways to resolve these conflicts:
Persuasion (make the other jx change laws to fit with US)