San Diego International Law Journal


Jorge A. Vargas

Document Type



In a quick search for cases involving foreign law that have been decided by California courts over the last two years, the results were not surprising: 100 cases were governed by Mexican law, 57 by Canadian law, 29 by Japanese law, 28 by German law, and 12 by Chinese law. I would like to pose two ideas before this learned audience: first, that becoming familiar with foreign law is a practical, intriguing and beneficial exercise for California judges and for American judges at large. And second, that Mexican law represents an emerging and a very large component of foreign law within our State and at the domestic level. Three simple words give the foundation to the idea that Mexican law is turning into the most prominent foreign law area in our State and in our country. These words are: 1) Geography; 2) People; and 3) Wealth.