Meeting of the Minds

This dissertation traces the development of a modern approach to comparative law that arose out of the fin-de-siècle critique of nineteenth-century legal thought in France and the United States. This critique undermined a mode of legal reasoning that assumed the common law and the civil code were internally-coherent and gapless systems of rules from which judges could logically deduce legal outcomes. As rapid social and economic changes swept across the Atlantic World, jurists influenced by reform movements sought to make the law more responsive to changing conditions, while also addressing the problem of legal indeterminacy posed by the critique of deduction.