Florida court quotes Professor William S. Dodge on international comity

A Florida appeals court earlier this month quoted Professor William S. Dodge in Amezcua v. Cortez, 2021 WL 113388 (Fla. Dist. Ct. App. 2021), a case enforcing a Mexican court’s embargo order prohibiting the sale of a condominium in Florida. Although foreign injunctions are not covered by the relevant state statute, the court held that the order could be enforced on the basis of international comity, relying on Dodge’s 2015 article “International Comity in American Law” published in the Columbia Law Review. 

Professor Dodge is Martin Luther King Jr. Professor of Law and John D. Ayer Chair in Business Law at UC Davis School of Law. He is a leading expert on international law, international transactions, and international dispute resolution, who served as Counselor on International Law to the Legal Adviser at the U.S. Department of State from 2011-12 and as a reporter for the American Law Institute’s Restatement (Fourth) of Foreign Relations Law from 2012 to 2018. Professor Dodge is a co-author of the casebook Transnational Business Problems and a co-editor of International Law in the U.S. Supreme Court: Continuity and Change, which won the American Society of International Law’s 2012 certificate of merit. He has authored more than 60 other publications in books and law reviews.